International Business Machines Corporation v. The Priceline Group Inc., et al., No. 15-cv-00137 (Burke, M.J.) (D. Del. Feb. 16, 2016)
- 7,631,346 | Entitled, “Method and System for a Runtime User Account Creation Operation Within a Single–Sign–On Process in a Federated Computing Environment”
- 5,961,601 | Entitled, “Preserving State Information in a Continuing Conversation Between a Client and Server Networked Via a Stateless Protocol”
- 5,796,967 | Entitled, “Method for Presenting Applications in an Interactive Service”
- 7,072,849 | Entitled, “Method for Presenting Applications in an Interactive Service”
Magistrate judge recommended denial of motion to dismiss.
Method and system for remotely entering, storing, and sharing addresses for GPS devices.
Ultimately, the magistrate recommended denying the pending motion to dismiss as to all claims. However, his rationale for doing so was split between the patents.
For the ‘346 and ‘601 patents, the court found that the claims were not directed to abstract ideas. The court found fault with Defendants attempts to overly simplify the inventive concept to “keeping track of prior communications during a conversation between computers.” The court ultimately found that for the ‘601 patent “the heart of the invention is more particular than simply ‘keeping track of communications’ amongst computers—it is the specific concept of recursively embedding state in continuations, in order to keep track of that content.” Further, the ‘601 patent supplied the necessary inventive concept through the “recursive embedding” limitations in the claims. As to the ‘346 patent, the court once again rejected Defendant’s proposed framing of the abstract idea and found that the “true heart of the invention is the utilization of SSO technology to automatically create an account at the service provider level on behalf of users who did not previously have such accounts, all in order to allow the user to access protected resources at the service provider.
For the ‘967 and ‘849 patents, the court found that, while the patents were directed to the abstract ideas of “locally storing information and resources at a user's computer and presenting a partitioned display,” there was sufficient inventive concept added by the claims to make the subject matter patent eligible.