Multimedia Plus, Inc. v. Playerlync, LLC
198 F. Supp. 3d 264
S.D.N.Y.2016Background
- Plaintiffs Multimedia Plus, Inc. and Multimedia Technologies, LLC own U.S. Patent No. 7,293,025 covering a "hosted learning management training system" that keeps large media files locally and transmits only minimal test data (employee ID and answers) to a central server for managerial oversight.
- The patent includes two independent claims: a system claim (Claim 1) and a method claim (Claim 12) describing local high-bandwidth media, a low-bandwidth connection to a remote server, and interfaces for employees and managers.
- Plaintiff alleged PlayerLync infringed the ’025 Patent; PlayerLync moved for judgment on the pleadings under Fed. R. Civ. P. 12(c), arguing the claims are invalid under 35 U.S.C. § 101 as directed to patent-ineligible subject matter.
- The court applied the two-step Alice/Mayo framework: (1) whether the claims are directed to an abstract idea; and (2) whether the claims contain an ‘‘inventive concept’’ that transforms the idea into patent-eligible subject matter.
- The court found the claims, stripped of generic computer language, are directed to the abstract concept of administering and collecting answers to tests and transmitting results for managerial review.
- The court held that the claimed components and their combination are conventional computer/Internet functions and do not supply an inventive concept; dependent claims likewise failed to provide meaningful limitations. Judgment on the pleadings granted; case dismissed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the claims are directed to an abstract idea under § 101 | The claims recite a specific hosted computing arrangement for training and are patent-eligible as an applied technological solution | Claims merely recite the longstanding practice of administering tests implemented with generic computers and networks | Claims are directed to the abstract idea of administering tests and collecting results |
| Whether the claims add an "inventive concept" under Alice step two | The combination of local high-bandwidth media plus low-bandwidth reporting to a central server is a practical technological improvement | The components are generic (local computer, server, low-bandwidth link, interfaces) and perform routine functions; no unconventional programming or algorithms | No inventive concept; generic computer implementation insufficient to transform the abstract idea into patent-eligible subject matter |
| Whether the ordered combination of claimed elements is inventive | The architectural arrangement produces practical efficiencies and is therefore inventive | Transmitting data between local and central computers is routine Internet-era functionality and not inventive | Combination is conventional data transfer; unpatentable |
| Validity of dependent claims | Dependent claims add meaningful limitations that preserve validity | Dependent claims are substantially similar and tied to the same abstract idea; add no meaningful limitation | Dependent claims are invalid for same reasons as independents |
Key Cases Cited
- Alice Corp. Pty. v. CLS Bank Int’l, 134 S. Ct. 2347 (2014) (establishes two-step framework for § 101 analysis)
- Mayo Collaborative Servs. v. Prometheus Labs., Inc., 566 U.S. 66 (2012) (requires an inventive concept to transform an abstract idea into patent-eligible subject matter)
- Bilski v. Kappos, 561 U.S. 593 (2010) (identifies abstract ideas as a § 101 exception)
- Ultramercial, Inc. v. Hulu, LLC, 772 F.3d 709 (Fed. Cir. 2014) (computer receiving and sending information over a network is generic and not inventive)
- buySAFE, Inc. v. Google, Inc., 765 F.3d 1350 (Fed. Cir. 2014) (generic computer functionality does not make an abstract idea patent-eligible)
- IpLearn, LLC v. K12 Inc., 76 F. Supp. 3d 525 (D. Del. 2014) (claims directed to instruction, evaluation, and review are abstract)
- TNS Media Research, LLC v. TiVo Research & Analytics, Inc., 166 F. Supp. 3d 432 (S.D.N.Y. 2016) (courts may decide § 101 at pleading stage post-Alice)