ART+COM Innovationpool GmbH v. Google Inc., C.A. No. 14-217 - RGA, April 28, 2016.

Andrews, J. Defendant’s motion for summary judgment for lack of patent-eligible subject matter is denied.

The patent-in-suit relates to a software-implemented method for providing pictorial representation of space-related data. Defendant claims that the asserted claim is directed to the abstract idea of storing image data, then repeatedly requesting specific data, which is then stored and displayed, like a visitor in a library reviewing atlases that include maps with differing scales. The court, following the analysis in Mayo and Alice, concludes that the invention is directed to the abstract idea of storing image data, then repeatedly requesting specific data, which is then stored and displayed. The court however does find an inventive concept in that the asserted claim recites a specific way of overcoming a problem which plagued prior art systems.