Summary of A Pty Ltd. Decisions from February 29, 2016

A Pty Ltd. v. Amazon.com, Inc., No. 15-cv-00154 (Pitman, J.) (W.D. Tex. Feb. 29, 2016)
A Pty Ltd. v. Ebay, Inc., No. 15-cv-00155 (Pitman, J.) (W.D. Tex. Feb. 29, 2016)
A Pty Ltd. v. Facebook, Inc., No. 15-cv-00156 (Pitman, J.) (W.D. Tex. Feb. 29, 2016)
A Pty Ltd. v. Google, Inc., No. 15-cv-00157 (Pitman, J.) (W.D. Tex. Feb. 29, 2016)
A Pty Ltd. v. Homeaway, Inc., No. 15-cv-00158 (Pitman, J.) (W.D. Tex. Feb. 29, 2016)

Patent(s):    

7,010572 | Entitled, “System for Handling Electronic Mail”

Disposition:               

Grant of Defendant’s Motion for Judgment on the Pleadings asserting claims are ineligible under § 101

Abstract Idea:

Yes

Something More:

No

Technology:              

Communications platforms for purchasers to contact sellers.

Summary:                 

The court determined that the claims were directed to the abstract idea of maintaining an address directory, or more specifically “using information in a message’s destination address to look up the recipient’s correct address.”  The court accepted the parties agreed construction of the term “email address” as “a string of characters complying with an addressing format for transmission of an email message by the SMTP protocol.”  In defending the pending motions, the patentee unsuccessfully attempted to latch onto the DDR Holdings case law by arguing that the inclusion of the “SMTP protocol” in the construction of the term “email address” save the patentable idea by necessarily making the problem to be solved as one uniquely based in computers.  Patentee also ultimately failed in persuading the court that there was an inventive concept by once again reaching for DDR Holdings and arguing that the problem to be solved was rooted in computer networks.  The court disagreed and held that the “claims address a long-standing problem (i.e. finding the correct destination address in order to make a message or package deliverable) in a computer setting.”