Multimedia Plus, Inc., et al. v. Playerlync, LLC

Multimedia Plus, Inc., et al. v. Playerlync, LLC, No. 14-cv-8216 (Pauley, J.) (S.D. N.Y. July 29, 2016)

Patent(s):    

7,293,025 | Entitled “Hosted Learning Management System and Method for Training Employees and Tracking Results of Same” 

Disposition:               

District Court granted a motion for judgment on the pleadings that the patent is directed to non-eligible subject matter under § 101. 

Abstract Idea:

Yes

Something More:

No

Technology:              

System and method of training employees via a hosted learning management training system. 

Summary:                 

The court quickly stripped down the alleged invention as unpatentable, stating that “[o]nce the generic, computing terminology is removed, it is clear that the ’025 Patent claims are directed at the abstract concept of administering a test: The ’025 Patent would provide users with instructional materials including test questions, collect answers to the questions, and send answers to a central server to be reviewed by a manager.” 

The court further found that the claims were directed to such generic computer components as: a “local computer,” a “training program including an interactive test having questions,” a “training session display,” a “first human-computer interface...enabling an employee to enter answers to questions,” a “low bandwidth connection,” a “remote computer server at a central location,” and a “second interface enabling a manager to access” the test information in real time. Accordingly, the abstract idea was not transformed into an “inventive concept.”