Tranxition, Inc. v. Lenovo (United States) Inc., No. 2015-1907, 2016 WL 6775967, at *1 (Fed. Cir. Nov. 16, 2016)
- 7,346,766 (“'766 patent”) | Entitled method and system for automatically transitioning of configuration settings among computer systems
- 6,728,877 (“'877 patent”) | Entitled method and system for automatically transitioning of configuration settings among computer systems
Motion for summary judgment on grounds of patent invalidity affirmed.
The '877 patent, and the '766 patent which is a continuation from the '877 patent, concern computer system upgrades. Typically, a person's computer system contains many individualized settings, such as email addresses, desktop settings, and stored passwords. When a computer is replaced, those settings do not appear on the new computer by default. In order for a replacement computer to behave like its predecessor, consumers must manually “migrate” the settings on the old computer to the new computer, which is a time-consuming process, resulting in user frustration and lost productivity. The '877 patent and the '766 patent propose to solve these problems by “automatic [ally] transitioning” these settings between computers.
The Court held that the ‘877 and ‘766 patents are related to unpatentable abstract ideas. The stated aim of the patents is to automate the migration of data between two computers. This is not sufficient under step one of Alice.
The patents fail step two of Alice. Here, the claim instructs a practitioner to (1) provide configuration information, (2) generate an extraction plan, (3) extract the configuration settings, (4) generate a transition plan, and (5) transition those settings to a new computer. These steps, both individually, and as an ordered combination, do not disclose an inventive concept. They merely describe a generic computer implementation, using “routine, conventional activities,” of the abstract idea, “which is insufficient to transform the patent-ineligible abstract idea into patent-eligible subject matter.”