Network Architecture Innovations LLC v. CC Network Inc, No. 16-914 (E.D. Tex. Apr. 18, 2017)
- 5,974,451 | Entitled “System and Method for Distributing Bulletins to External Computers Accessing Wide Area Computer Networks”
Grant of Defendant’s 12(b)(6) motion
System and method of using a network access system to distribute targeted bulletins (e.g., advertisements) to users accessing a wide area computer network, such as the Internet
The Court found the claims were directed to the abstract idea of systems and methods of appending bulletins to information being transmitted over a network. The patent’s purported purpose of identifying a user in order to optimally match advertising is no different than the “age-old” practice of including advertising inserts in a newspaper. The Court rejected the Plaintiff’s assertion that the claims are directed to improvements in computer and network technology, holding that there were no such limitations in the claims. The court then held that there was no inventive concept in the limitations, individually or as an ordered whole. The claimed bulletin server is not a new type of server but a generic one that stores a plurality of servers. The Court concluded the claims were directed to unpatentable subject matter.