Yodlee Inc. v. Plaid Technologies Inc., No. 1-14-cv-01445 (Burke, M.J.) (D. Del. May 23, 2016)
- 6,199,077 | Entitled, “Server-side web summary generation and presentation”
- 6,317,783 | Entitled “Apparatus and methods for automated aggregation and delivery of and transactions involving electronic personal information or data”
- 6,510,451 | Entitled “System for completing a multi-component task initiated by a client involving Web sites without requiring interaction from the client”
- 7,263,548 | Entitled “Method and apparatus for restructuring of personalized data for transmission from a data network to connected and portable network appliances”
- 7,424,520 | Entitled “Method and apparatus for restructuring of personalized data for transmission from a data network to connected and portable network appliances”
- 7,752,535 | Entitled “Categorization of summarized information”
- 8,266,515 | Entitled “Categorization of summarized information”
Recommended grant-in-part and denied-in-part
Collecting and organizing data from websites
The magistrate recommended the decision be granted-in-part and denied-in-part. In order to give the Court “as full an understanding as possible of the meaning of key claim terms” asserted, and in order to seek to narrow the scope of the dispute from the broad swath of the claims subject to the motion to dismiss, the Court construed the claims in a previous order.
As to ‘077 patent, the magistrate could not conclude that the claims embodied the abstract idea of “gathering data specific to a person from a plurality of Internet sites” but nonetheless proceeded to evaluate Alice step two. The magistrate found several factual issues precluded disposition under a motion to dismiss, including whether procedures gathering data from a website were in “well-understood, routine, and conventional activities” and whether there was any preemption of other applications gathering data from websites.
As to the ‘783 patent, the magistrate faulted defendant’s characterization of the abstract idea as “retrieving and storing personal information from multiple sources”, and instead found the claim was directed to “a method of retrieving a particular type of personal information: that which would otherwise be blocked off behind a wall of security, such that verification of one's identity was necessary to access it.” Because defendant failed to carry its burden as to this patent, the magistrate recommended denying the motion as to this claim. At any rate, factual issues regarding the conventionality of the claims also precluded dismissal.
The magistrate found that the ‘451 patent was directed to the abstract idea of “the concept of a (computer-based) method for identifying sub-tasks of a larger task, executing them and communicating the results to a user.” Functional language in the limitations did not add an inventive concept.
The ‘548 and ‘520 claims were directed to the abstract idea of “transforming data from one form to another.” Although the claims of this matter were directed to the same problem as those in the Federal Circuit decision Messaging Gateway Solutions v. Amdocs, the claims in Messaging Gateway included sufficient specificity to present a solution. The claims here failed to add such an inventive concept.
The magistrate did not find defendant had met its burden to show the ‘535 and ’515 patents were directed to the abstract idea of “summarizing purchase data for a business purpose.” The magistrate cited the specifications for support that the claimed system will “grow and improve” its ability to categorize the data. The magistrate again found as to these claims factual disputes as to the conventionality and preemptive effect of the claims.