Visual Interactive Phone Concepts, Inc. v. United States Cellular Corp., No. 11 C 5289, 2016 WL 6770861, at *1 (N.D. Ill. Nov. 15, 2016)
- 5,724,092 (“the '092 patent”) | Entitled “Videophone Interactive Mailbox Facility System and Method of Processing Information.”
Motion for judgment on the pleadings granted.
The primary innovative feature of the ‘092 patent is that it provides for a videophone interactive mailbox facility system that allows the user to view products and services; review letters, bills and payments for services/products which can be viewed on the videophone screen, such that the user can review the pertinent information and immediately decide if it is correct and then transmit the appropriate letter, bill, and/or payment for services or products.
The court concluded that the ‘092 patent does not claim patentable subject matter under 35
U.S.C. § 101.
Under the first step of the Alice framework, a comparison of the '092 patent claims with prior art revealed that the claims focus on the functionality of conducting a transaction and disclose no more than the abstract idea of conducting transactions using conventional computer components, a telephone and centralized data storage.
The '092 patent, when considered with all of its components, lacks inventive concept, and fails the second step of the Alice framework. Here, the patent was not directed at overcoming problems in computer technology, rather the claims relate to performing commercial transactions using conventional equipment. The claimed videophone can consist of generic computer components and a telephone that perform ordinary functions in a conventional manner. The '092 patent presents a risk of broad preemption of the abstract idea of conducting transactions over a network.