Emmanuel C. Gonzalez v. Infostream Group, Inc.

Emmanuel C. Gonzalez v. Infostream Group, Inc., No. 14-cv-00906 (Payne, M.J.) (E.D. Tex. Feb. 6, 2016)

Patent(s):

  • 7,783,665 | Entitled, “Effective file-sharing among virtual environments” 
  • 7,558,807 | Entitled, “Host website for digitally labeled websites and method”

Disposition:

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

Abstract Idea:

No

Something More:

Yes

Technology:

Method for making digital labels for web content and websites implementing such labels. 

Summary:

The Court determined that the claims were not directed to the asserted abstract idea of “gathering and organizing data into a searchable format,” because, while gathering data could be abstract, “producing a label” is not abstract. Producing a label, in the context of the patents, is not abstract because it is a specific and concrete implementation of data storage.  The ‘807 patent is similarly not directed to an abstract idea because it is directed to a computer system configured to use the digital labels. The magistrate judge held that the patent claims also included an inventive concept because the claims were directed at improving the functionality of the computer system itself.