Cyberfone Systems, LLC v. Lexmark International, Inc., C.A. No. 14-1489–SLR, October 8, 2015.
Robinson, J. Defendant’s motion for judgment on the pleadings is granted.
The disputed technology relates to a data transmission processing. The patent is challenged as containing unpatentable subject matter under § 101. The court observes that § 101 jurisprudence has evolved after Alice from almost complete rejection of patentability for computer programs to almost complete acceptance of them. The court looks to DDR as a benchmark such that claims must describe a problem and solution rooted in computer technology, and the solution must be specific enough to preclude pre-emption, and innovative enough to override routine and conventional use of the computer. The court concludes that although the problem addressed by the asserted claims is rooted in computer technology, the claimed solution is not disclosed with enough specificity to transform the abstract idea into a patentable application, thus risking the monopolization of the abstract idea itself.