Mobile Telecommunications Techs., LLC v. Blackberry Corp.

Mobile Telecommunications Techs., LLC v. Blackberry Corp., No. 3:12-CV-1652-M, 2016 WL 2757371, at *1 (N.D. Tex. May 12, 2016)

Patent(s):  

  • 5,809,428 | Entitled “Method and device for processing undelivered data messages in a two-way wireless communications system”
  • 5,894,506 | Entitled “Method and apparatus for generating and communicating messages between subscribers to an electronic messaging network”

Disposition:               

Motion to dismiss for invalidity granted. 

Abstract Idea:

Yes for both patents.

Something More:

No for both patents.

Technology:              

“Utilizing a two-way communication network to process data messages that cannot be successfully transmitted from a network operations center ("NOC") to a mobile unit” (‘428 patent); “electronic messaging system that provides coded communications between messaging terminals” (‘506 patent).

Summary:                 

The Court found the ‘428 patent to be invalid under § 101 because it was “directed to the basic idea of sending and storing messages, which is not rooted in computer technology.” Further, the ‘428 patent did not contain an inventive concept sufficient to transform the abstract idea into patentable material under Alice’s second step because it only used generic computer components to perform the abstract idea.

The Court found the ‘506 patent to be invalid under § 101 because the patent was “directed to a method for effectuating the abstract concept of coded communication,” and was thus, an abstract idea. Further, the ‘506 patent, like the ‘428 patent, did not contain an inventive concept sufficient to transform the abstract idea into patentable material because it only used generic computer components to perform the abstract idea.