Williamson v. Citrix Online, LLC, et al., No. 11-cv-02409 (Otero, J.) (C.D. Cal, Feb. 17, 2016)
6,155,840 | Entitled, “System And Method For Distributed Learning”
Grant of motion for summary judgment of unpatentability.
Online learning environments which allow for interaction between the presenters and audience members.
The Court determined that the claims were directed to the abstract idea of creating a virtual, interactive learning environment and a comparison to a classroom experience was in keeping with the full scope of the specification. The court brushed off Patentee’s arguments that “real time, interactive distance learning” "necessarily requires a technology solution” in summary fashion, noting that the mere fact that a method can only be performed using a computer does not elevate an abstract idea patentable. In considering whether the patent claims added an inventive concept, the court found that none of the asserted claims meaningfully limit the abstract idea of creating a virtual, interactive learning environment. Rather, the “majority of the steps of the asserted claims comprise the abstract concept of creating a virtual environment wherein participants can interact in real time” and the asserted claims themselves do not require any specific hardware or software.