Apple Inc. et al. v. Smartflash LLC

Apple Inc. et al. v. Smartflash LLC 2015-00033 (PTAB May 26, 2016)


8,336,772 | Entitled, “Data storage and access systems” 


Final Written Decision granting petition 

Abstract Idea:


Something More:



Data storage on portable multimedia devices 


The PTAB concluded the claims were directed to the abstract idea of “conditioning and controlling access to content based on, for example, payment,” and although the specification discussed application to the Internet, the claims were directed to broader application. Such conditional access based on payment is a fundamental economic practice. All technological limitations were already known, and not even in combination created an inventive concept. Nor were the claims limited to solving problems arising from the Internet or computer networks. Storing multiple kinds of information in the same place was not novel, as storing names and numbers together is an old process. Even to the extent the claims are limited to a technological environment, the risk of preemption here is too great. Other claims of the same patent were invalidated in related matters 2015-00031 and 2015-00032 and similar claims of US Patent No. 7,334,720 were invalidated in 2014-00190, 2015-00028, and 2015-00029 on essentially the same grounds.