Tridim Innovations LLC v. Amazon.com, Inc., No. 15-cv-05477 (Donato, J.) (N.D. Cal. Sept. 19, 2016)
- 5,838,326 | Entitled, "System for Moving Document Objects in a 3-D Workspace"
- 5,847,709 | Entitled, "3-D Document Workspace with Focus, Intermediate, and Tertiary Spaces"
The District Court granted a motion to dismiss for invalidity on the grounds of non-eligible subject matter under § 101.
A 3-D document workspace system for interacting with large number of documents where the system is hierarchical in that it divides the documents into three separate areas on workspace depending on interaction rates with the documents.
The court found that the claims were directed to the abstract idea of retrieving and arranging documents based on frequency of use. It noted that the claims were only defined in terms of their functions which related to this abstract idea, and also noted that the “patents do not involve special software or hardware,” and that the patents themselves state that “a person of skill in the art could implement the invention on any commercially available computer with the functionality for ‘manipulating graphical objects in a three dimensional space.’”
The Court then determined that neither the problem nor solution the patents addressed (limited screen space and arranging documents based on frequency of use) was rooted in computer technology, and in fact, the patentee even admitted that the patent was intended for use with a typical computer. “But applying a commonplace method of organization to a particular technological environment does not constitute an inventive concept, and the patents here fall squarely within the type of inventions that the Supreme Court explicitly found invalid in Alice."