A California court has granted summary judgment invalidating claims of four patents related document linking technology as patent ineligible abstract ideas under the Supreme Court’s Alice decision. Bascom sued Facebook and Linkedin in 2012 on patents relating to methods for publishing, distributing, relating and searching document objects on computer networks. The patents claimed methods that allowed users to establish relationships between document objects located on the Internet and maintain link directories. Following the Supreme Court’s decision in Alice, the defendants filed motions for summary judgment of patent invalidity under § 101. Applying the two-step Alice test, the court agreed with defendants that establishing relationships between documents is a centuries-old concept that can also be performed by the human mind. The court ruled that Bascom’s patents describe an abstraction having no particular concrete or tangible form. Finding the Federal Circuit’s Ultramercialdecision instructive, the court ruled that “allowing users to generate relationships between document objects and storing those relationships separately from the document objects simply describes the abstract idea of creating, storing and using relationships between objects.” According to the court, “establishing relationships between document objects and making those relationships accessible is not meaningfully different from classifying and organizing data.” The court further compared Bascom’s patents to other recently invalidated software patents. Evaluating the claims under step two of the Alice patent eligibility test, the court ruled that Bascom’s patents failed to include any inventive concept. The court rejected Bascom’s proffered expert testimony as conclusory, and held that Bascom’s patents require nothing beyond a generic computer. The court decided that computer-based limitations recited in the claims failed to demonstrate an “inventive concept” that transforms Bascom’s claims into patentable subject matter.
Bascom Research LLC v. Facebook Inc., No. 3:12-cv-06293 (N.D. Cal. Jan. 2, 2015) (Illston, J.).