2-Way Computing, Inc. v. Grandstream Networks, Inc.

2-Way Computing, Inc. v. Grandstream Networks, Inc., No. 16-1110 (D. Nev. Oct. 18, 2016)


  • 5,434,797 | Entitled “Audio communication system for a computer network”


Denial of Defendant’s Motion to Dismiss

Abstract Idea:


Something More:



Method of controlling audio systems using computers


The court found Grandstream’s analysis that the system had been long-practiced conflated Section 102/103 with Section 101 invalidity analysis.  The court did not agree the claim was abstract but was rather a “concrete, physical task.” The computer system was not a generic-functioning computer but rather a “computer station for a particular, concrete method of communication inherently tied to a machine with particular physical capabilities.” Further, “[t]he information is converted from and to physical sound waves by a machine.” Having so decided, the court did not analyze the inventive concept.