On November 15, 2021, the United States District Court for the Eastern District of Texas found that the asserted claims directed at data collection, storage, management, and access were abstract, but refused to dismiss the claims under the second step in the Alice analysis. Gravel Rating Systems, LLC v. McAfee, LLC, Case No. 4:21-CV-259-ALM.  

Section 101 of the patent statute states that “[w]hoever invents or discovers any new and useful process, machine, manufacture, or composition of matter, or any new and useful improvement thereof, may obtain a patent therefor, subject to the conditions and requirements of this title.”  35 U.S.C. § 101.  The Supreme Court has “long held that this provision contains an important implicit exception: Laws of nature, natural phenomena, and abstract ideas are not patentable.”  Alice Corp. Pty. v. CLS Bank Int’l, 573 U.S. 208 (2014).  

Plaintiff Gravel Rating Systems, LLC (“Gravel”) asserted patent claims against defendant McAfee, LLC (“McAfee”).  The asserted patent sought to improve network-based knowledge sharing through a “self-organizing system knowledge base.”  McAfee brought a Rule 12(b)(6) motion to dismiss, arguing that the asserted claims were invalid under Section 101.  

Applying the Alice analysis, the district court found that the asserted claims were directed to the abstract idea of managing, organizing, and presenting information, and that the asserted claims fall within the class of claims related to abstract ideas of collecting information, analyzing it, and displaying certain results of the collection and analysis.  

However, the district court went on to find that McAfee failed to establish that the asserted claims lacked an inventive concept.  In particular, the district court found that the patent was directed to improvements in network-based knowledge sharing and that the asserted patent provided several advantages over the prior art system’s organization and presentation of information.  The district court also accepted as true Gravel’s allegations that suggest that the claimed invention was directed to an improvement in the computer technology itself and not directed to generic components performing conventional activities.