TNS Media Research, LLC v. TiVo Research and Analytics, Inc.

TNS Media Research, LLC v. TiVo Research and Analytics, Inc.,  No. 11-cv-04039 (Shira, J.) (S.D.N.Y. Feb. 22, 2016)

Patent(s):                   

  • 7,729,940 | Entitled, “Analyzing Return on Investment of Advertising Campaigns by Matching Multiple Data Sources” 
  • 8,000,993 | Entitled, “Using Consumer Purchase Behavior for Television Targeting”

Disposition:               

Motion for summary judgment of invalidity granted.

Abstract Idea:

Yes

Something More:

No

Technology:              

Method for tracking consumer purchases to analyze value of advertising campaigns.

Summary:      

The Court determined that the claims were directed to the abstract idea of digital, doubleblind matching of collected purchase data and program delivery data to individual households.  The court found that though computers make the process more efficient, the entirety of the asserted invention could be performed by a person. The court further held that the claims did not include further inventive concept because the claims were directed to generic computing machines.