Genband US LLC v. Metaswitch Networks Corp. et al.

Genband US LLC v. Metaswitch Networks Corp. et al., No. 14-cv-00033 (Payne, M.J) (E.D. Tex. Jan. 6, 2016)

Patent(s):

6,772,210 | Entitled, “Method and Apparatus for Exchanging Communications Between Telephone Number Based Devices in an Internet Protocol Environment”

7,047,561 | Entitled, “Firewall for Real-Time Internet Applications”

Disposition:

Magistrate judge recommended denial of motion for summary judgment as to ineligible subject matter.

Abstract Idea:

No

Something More:

N/A, but yes.

Technology:

Telephone internet communications whereby message addresses are translated between two different IP networks with two different telephone number devices.

Summary:

Contrary to Metaswitch’s assertions, the court found that the claims of the ’210 patent are not directed to “manipulation of binary data” in an “abstract way.”  Rather, the claims are directed to a specific set of operations confined to a particular context that help solve a problem specifically found in computer networks that does not arise in the brick and mortar context.  The court went on to state that even if claim 1 of the ’210 patent were an abstract idea, it was patent-eligible because it recites a combination of elements (a first and second telephone number based device in two different connected IP networks) and delimits how the elements are used. Similarly, the ’561 patent claims were not directed to an abstract idea but rather a specific type of data structure unique to a specific class of computer networks that require packets to be associated with certain networks channels and be applied to a different firewall component depending on packet type.  Moreover, the language of the claim recited “significantly more” in that it was implemented in a specific non-generic computer system that improved the function of the computer itself.   In recommending denial of the motion for summary judgment as to in-eligible subject matter, the magistrate judge determined that the preamble to the claims was limiting as it explained the structural context of the invention including how the networks are coupled.