Intellectual Ventures I LLC v. Symantec Corporation, et al; Intellectual Ventures I LLC v. Trend Micro Incorporated, et al., C.A. Nos. 10-1067 – LPS; 12-1581–LPS, April 22, 2015.
Stark, C. J. Defendants’ motions for judgment of patent invalidity are granted in part and denied in part.
A trial against Symantec resulted in a jury verdict of $17 million. A section 101 decision was reserved for post-trial briefing. The Trend Micro trial is scheduled for May. The standard of proof on a § 101 motion is unsettled by the judge finds that under the clear and convincing standard it would find the ‘050 and ‘142 patents to be patent ineligible. The court would not find the ‘610 patent, ineligible even under the lesser preponderance of the evidence standard The ‘050 patent relates to a method of receiving information related to a file from a querying computer. The court finds the claims are directed to an abstract idea and not necessarily rooted in computer technology. The limitations do not add an “inventive concept” as they do nothing more than limit the abstract idea to SPAM email detection. The claims of the ‘142 patent are directed to generic implementation of an abstract idea – implementing well-known post office functionality using a computer. The ‘610 patent, on the other hand, is directed to screening for computer viruses, which has computer-centric implications which cannot be broadly abstracted away.
