Device Enhancement LLC. v. Amazon.com, Inc.

Device Enhancement LLC. v. Amazon.com, Inc., No. 15-cv-762 (Robinson, J.) (D. Del. May 17, 2016)

Patent(s):    

7,747,683 | Entitled, “Method and System for Operating Applications for Remote Terminal Devices” 

Disposition:               

Motion to dismiss on grounds of non-eligible subject matter under § 101 granted.

Abstract Idea:

Yes

Something More:

No

Technology:              

Method and system for allowing a user of a terminal device to remotely operate upgraded and/or advanced applications without the need for upgrading the client side application or computational resources. 

Summary:                 

The court found that the patent was directed to an abstract idea and that the method of performing the idea was so untied to any particular computer structure that it “preempts virtually all possible ways of performing the claimed method because the very steps of the method comprise nothing more specific than the underlying idea itself. In other words, “the claim’s tie to a digital computer [does] not reduce the preemptive footprint of the claim since all uses of the [idea are] still covered by the claim.” Citing Bilski I

The Court noted specifically that the following disclosures in the specification indicated that the method was untied to sufficient structure: 

  • The “terminal device” can be “any electronic unit capable of executing software,” including a cellular phone and TV (3:45-48), and would include devices which are not mobile or portable (5:61-67). 
  • The content delivery application may be any form from a game to a “3-D graphical presentation” to a “location based application.” (3:54-59) 
  • The client-side component is “generic.” (4:12-13) 
  • The data network is similarly known and satisfied by a wide variety of networks from the Internet to a wireless data network to cable TV. (3:42-44)

Finding pre-emption, the Court summarized the performance of the claimed invention as:
The claimed method, then, generally provides for the installation of a generic client-side application on the terminal device and the installation of a corresponding remote application on the server (which handles most of the graphical processing). The server exchanges data with the terminal device. Tasks are split between the client-side application and the remote application, albeit without further guidance from the patent. The processed content is then transmitted and the client-side application renders the content and responds to messages.