Tele-Publishing, Inc. v. Facebook, Inc.

Tele-Publishing, Inc. v. Facebook, Inc., et al., 09-cv-11686 (Woodlock, J.) (D. Mass. 2017)

Patent(s):

  • 6,253,216 | Entitled “Method and apparatus for providing a personal page”

Disposition:               

Grant of Defendant’s Motion to Dismiss

Abstract Idea:

Yes

Something More:

No

Technology:              

Methods and apparatus for providing a personal page over a computer network

Summary:                 

Defendant’s motion for summary judgment that the asserted claims were invalid under 35 U.S.C. §101 was granted. First, the court determined that the claims were directed to “the abstract idea of collecting, storing, and selectively sharing personal information.” In reaching this determination, the court cited several Federal Circuit and district court holdings that held similar claims directed to collecting, storing, and sharing were abstract ideas. The court next determined that the claims did not contain the necessary inventive concepts required to transform the claims into patent-eligible subject matter. The court determined the claims relied upon generic technologies, all the claimed steps could “be performed using a pencil and paper or the human mind,” and the claims did not offer a new solution to a technological problem. Further, the court concluded that if the claims were characterized as an inventive conceptive, it “would risk disproportionately tying up others’ use of the abstract idea of collecting, storing, and selectively sharing personal information.” Thus, the court held that the claims were not directed to patent-eligible subject matter and thus invalid.