Intellectual Ventures I LLC et al v. Erie Indemnity Company et al., No. 1-14-cv-00220 (Hornak, D.J.) (W.D. Pa. Aug. 4, 2016)
- 7,757,298 | Entitled “Method and apparatus for identifying and characterizing errant electronic files”
Grant of Defendant’s Motion to Dismiss for ineligible subject matter under § 101.
Marking and identifying illicit documents for deletion.
The court found the claims are directed to the abstract idea of “identifying and categorizing files based on a set of predetermined criteria.” This merely computerizes a long-standing task, identifying and categorizing illicit files, and these functions can be performed by humans. Limitations describing the type of source code used to identify files were merely routine computer applications. Plaintiffs’ argument on these limitations amounts to a novelty argument.