Visual Memory LLC v. Nvidia Corporation, C.A. No. 15-789-RGA, May 27, 2016.
Andrews, J. Defendant’s motion to dismiss is granted. Oral argument took place on February 18, 2016.
Defendant claims that the patent-in-suit is directed to patent-ineligible subject matter under section 101 and Alice. It describes a computer system with a three-tiered memory hierarchy. With respect to Step one of the Alice analysis, the court finds that the asserted claims are directed to the abstract idea of categorical data storage. As for step two, the court finds that the “programmable operational characteristics” limitation fails to supply the required inventive concept. Without an explanation of the mechanism for how the result is accomplished it cannot supply an inventive concept.