Messaging Gateway Solutions, LLC v. Amdocs, Inc., et al, C.A. Nos. 14-732- RGA; 14-733- RGA; 14-734- RGA14-735- RGA; 14-736- RGA; 14-737- RGA; April 15, 2015.

Andrews, J.  Defendants’ motions for judgment on the pleadings of invalidity pursuant to section 101 are denied.  Plaintiff’s motion for judgment on the pleadings of validity pursuant to section 101 is granted.

The court raises the issue of the correct standard of proof to apply in a 101 case but does not reach that issue. Defendants claim that the representative claim is abstract and thus unpatentable because it relates to receiving a message in one format, changing it into another format, and sending to its destination.  Plaintiff claims the claim is securely tethered to a tangible idea of a particular way to allow a mobile device to communicate with an Internet server.  The court finds that the claim is directed to the abstract idea of translation.  It also finds that the claim contains an inventive concept sufficient to render it patent-eligible.  The claim is directed to a problem unique to text-message telecommunication and the solution is tethered to the technology that created the problem. It also contains sufficient limitations to prevent it from preempting an abstract idea.  Questions of obviousness and novelty are issues for another day.