Finjan, Inc. v. Blue Coat Systems, LLC, Case No. 15-cv-03295-BLF (Labson Freeman, J.) (N.D. Cal. Dec. 13, 2016)
- 8,677,494 | Entitled, “Malicious Mobile Code Runtime Monitoring System and Methods”
Court denied Defendant’s motion for judgment on the pleadings that the patent was invalid for failure to claim patent-eligible subject matter.
Systems and methods for protecting devices on an internal network from code, applications, and/or information downloaded from the Internet that perform malicious operations.
The court found that the claims were directed to the abstract idea of “merely recit[ing] the familiar concepts of gathering data, analyzing that data for certain characteristics, and storing the results of that analysis. These are fundamental concepts germane to any type of content analysis.” But, in step two of the Alice inquiry, the court determined that when taken as an ordered combination, the claims included both spatial and temporal alterations to virus protection at the time of the invention. At that time, virus protection was localized and reactive. The invention moved malware profiling from end-user computers to an intermediate location on network, and also shifted the profile logic from one that must be applied to single, complete files to extracted aspects or components of a file after it has been decomposed. The court’s determination was based in large part on the specification of a parent patent that had been incorporated into the patent-in-suit by reference.