Rothschild Location Technologies LLC v. Geotab USA, Inc., No. 15-cv-682 (Schoeder, J.) (E.D. Tex. May 16, 2016)
8,606,503 | Entitled “System, Report, and Method for Generating Natural Language News-Based Stories”
District Court adopting Magistrate’s recommendation to grant motion to dismiss on grounds of non-eligible subject matter under § 101.
System and method for automatically generating a series of natural language news-based stories to be presented via a digital interface or printed publication.
The court first responded to patentee’s objections that the magistrate judge’s recommendation should be rejected on the grounds that the magistrate had arrived at his recommendation based solely on the content of the patent at issue and had declined to convert the motion to dismiss to a motion for summary judgment to consider plaintiff’s expert’s declaration. The district judge brushed aside this argument, noting that recent Federal Circuit precedent supported the magistrate judge’s approach to considering a motion to dismiss on patent eligibility.
The district judge agreed with the magistrate’s finding that the ’503 Patent is directed toward the abstract idea of address retrieval which “simply relate[s] to ease, accuracy, and efficiency benefits achieved when any fundamental or well-known concept is implemented on a computer device.”
The district judge agreed with the magistrate judge’s finding that a GPS device performing generic computer tasks does not transform the claims into patent-eligible subject matter. The ’503 Patent itself suggests that GPS devices were conventional at the time the patent was filed. See ’503 Patent 1:22 (GPS devices “are everywhere”). More specifically, the claims direct GPS devices to perform generic computer tasks: “receiving” a request, “determining” an identifier, “retrieving” an address, and “transmitting” the address. The “transmitting” task may be performed using “any...type of communication protocol [+] or system [+] currently existing or to be developed for wirelessly transmitting data.” Thus, the structures cited in the claims did not transform the claims into patent-eligible subject matter.