CalAmp Wireless Networks Corp. v. ORBCOMM, Inc., No. 3:16CV906-HEH, 2017 WL 536833, at *1 (E.D. Va. Feb. 9, 2017)
- U.S. Patent No. 6,850,839 (“the '839 Patent”), entitled “Time Sensitive Article Tracking Device.”
Motion to dismiss on grounds of patent invalidity granted.
The '839 Patent claims a system and method of tracking an object by: (1) assessing the current location of the object; (2) obtaining the object's required location for the corresponding time; (3) determining whether the object is in the required location; and (4) requesting information in response to that determination.
The Court held that the ‘839 Patent is related to an unpatentable abstract idea. The Court explained that beginning at Alice step one, determining whether an object is in the right place at the right time, as claimed in the '839 Patent, fell squarely into a well-recognized category of claims directed to abstract ideas.
At the second stage of the Alice framework, the Court found that the '839 Patent did not add the requisite inventive material to transform the Patent into more than an abstract idea. The Patent holder CalAmp argued that the '839 Patent contained an inventive concept because a subset of database records is stored on the tracking device while the complete database is stored on the server, and that this specific arrangement of database records provided technological improvements over the prior art systems. The Court rejected this argument and explained that long before the filing of the Patent, computer systems had been configured in such a way to allow remote terminals to access information stored on a centralized database. Thus, applying this database structure to a tracking system was far from unconventional and insufficient to establish an inventive concept.