Motorola Mobility, LLC, v. Intellectual Ventures I, LLC, CBM2015-00004 (PTAB, March 21, 2016)
6,658,464 | Entitled “User station software that controls transport, storage, and presentation of content from a remote source”
Claims are patentable under§ 101.
Computer implemented transport of electronic information objects, and, more specifically to a method and software for automatically pre-fetching additional data objects referenced by a first data object.
The PTAB found that the ‘464 was un-patentable because it was directed at the abstract idea of “selecting, transporting, storing, and displaying content.” The invention was analogous to purchasing a book from a book store or renting a video from a video store. Additionally, the claims lacked an inventive concept because they merely recite the use of generic computer components for their ordinary uses. Nothing claimed improved the function of the computer itself or any other technological field. The PTAB rejected the argument that the claims were narrow and specific and noted that “[a]n abstract idea does not become nonabstract by limiting the invention to a particular field of use or technological environment such as the Internet.”