Multimedia Plus, Inc., et al. v. Playerlync, LLC, No. 14-cv-8216 (Pauley, J.) (S.D. N.Y. July 29, 2016)
7,293,025 | Entitled “Hosted Learning Management System and Method for Training Employees and Tracking Results of Same”
District Court granted a motion for judgment on the pleadings that the patent is directed to non-eligible subject matter under § 101.
System and method of training employees via a hosted learning management training system.
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.”