Umbanet v. Epsilon Data Management LLC

Umbanet v. Epsilon Data Management LLC, No. 16-682 (E.D. Tex. Apr. 18, 2017)

Patent(s):

  • 7,444,374 | Entitled “Electronic mail software with modular integrated authoring/reading software components including methods and apparatus for controlling the interactivity between mail authors and recipients”
  • 7,076,730 | Entitled “Electronic mail software with modular integrated authoring/reading software components”

Disposition:               

Grant of Defendant’s 12(b)(6) motion as to ‘374 patent, denial as to ‘730 patent

Abstract Idea:

Yes (‘374 patent)

Something More:

No (‘374 patent)

Technology:              

  • System for sending non-text portions of a message, such as a picture or spreadsheet file, along with an email (‘730 patent)
  • System for sending non-text portions of a message, such as a picture or spreadsheet file, along with an email, and controlling access to certain messages based on the “role“ of the user receiving the message. (‘374 patent)

Summary:                 

As to the ‘374 patent, the Court turned to Federal Circuit precedent, including Preservation Wellness and Intellectual Ventures I, to conclude that the claims were directed to the abstract idea of providing selective or particularized access to an email. Such selective access to information based on an individual’s role is only an abstract idea. Conditioning access to parts of an email message according to the “role” of the recipient did not add an inventive concept as such conditioned access was well known. 

As to the ‘730 patent, the Court tersely concluded that claim construction would be necessary to determine if the claims have a sufficiently specific implementation, and further noted a potential Section 112(6) dispute precluded disposition as to this patent at the pleadings stage.