A California district court denied defendant’s motion for judgment on the pleadings that a patent covering methods and systems for organizing meetings is invalid under 35 U.S.C. § 101. The defendant argued that the claims are directed to the abstract idea of organizing a meeting and using software to execute that idea on a computer. The patentee countered by arguing that the claims solved the technical problem of enabling meeting attendees to send and receive messages without divulging their e-mail addresses. The defendant responded, explaining that such an idea was abstract and well-known, and pointing out that newspapers once offered a similar solution to permit responses to personal ads. The court agreed that the challenged claims are conceptually similar to other types of anonymous communications. Nonetheless, the court explained that “[t]he patent does not merely teach using generic computer programming to address a pre-existing need for anonymous communications in other situations,” instead, the patent is directed specifically to problems that would arise in electronic communications. The court considered the issue a close one and expressed willingness to reconsider it on a fully-developed record, but in light of the Supreme Court’s instruction in Alice to not apply the “abstract idea” limitation too broadly, the district court denied the defendant’s motion for judgment on the pleadings.
Mobile-Plan-It LLC v. Facebook Inc., No. 14-cv-01709 (N.D. Cal. Apr. 20, 2015)