BASCOM Global Internet Services, Inc. v. AT&T Mobility LLC et al.

BASCOM Global Internet Services, Inc. v. AT&T Mobility LLC et al., No. 2015-1763 (Fed. Cir. Jun. 27, 2016) 

Patent(s):    

5,987,606 | Entitled, “Method and system for content filtering information retrieved from an internet computer network”

Disposition:               

Vacatur and remand of grant of motion to dismiss 

Abstract Idea:

Yes

Something More:

Yes

Technology:              

System for filtering internet content  

Summary:                 

The Federal Circuit agreed with the district court that the process of filtering content is an abstract idea because it is a “a longstanding, well-known method of organizing human behavior, similar to concepts previously found to be abstract.” The court distinguished the claims at issue from the claims treated in the Federal Circuit’s decision Enfish LLC v. Microsoft Corp, as the claims here are not obviously directed to a non-abstract idea, and are not “unambiguously directed to an improvement in computer capabilities.” The court found no need to incorporate claim limitations into its own expression of the abstract idea as it did in Enfish. As to the inventive concept, the court agreed with the district court that the limitations taken individually did not add an inventive concept, but disagreed with the district court’s analysis of the ordered combination of the limitations, which it found looked similar to an obviousness analysis. That is error because, as is the case here, “an inventive concept can be found in the non-conventional and non-generic arrangement of known, conventional pieces.”