Two-Way Media Ltd. v. Comcast Cable Communications, LLC

Summary

The United States Court of Appeals for the Federal Circuit affirmed a district court judgment that claims in four Two-Way Media patents were ineligible under 35 U.S.C. § 101. Applying the Alice framework, the court held that the claims were directed to abstract ideas involving the transmission, routing, monitoring, and measurement of real-time audio/visual information. The court further held that the claims lacked an inventive concept because they recited generic computer and network components performing conventional functions.

Holdings

1. The representative claims are directed to the abstract idea of sending information, directing the sent information, monitoring receipt of the information, and accumulating records concerning its receipt because they use result-based functional language without sufficiently describing a non-abstract means of achieving those results.
2. The representative claims of the '187 and '005 patents lack an inventive concept and therefore do not transform the abstract ideas into patent-eligible applications.
3. The representative claims of the '622 patent are directed to the abstract idea of monitoring delivery of real-time information to users, and the representative claims of the '686 patent are directed to the abstract idea of measuring delivery of real-time information for commercial purposes.
4. The representative claims of the '622 and '686 patents lack an inventive concept because they require only conventional computer and network components performing ordinary functions in a conventional arrangement.
5. The district court did not err in excluding materials concerning novelty and nonobviousness because eligibility and novelty are separate inquiries, and evidence relevant to §§ 102 and 103 does not establish eligibility under § 101.

Questions Presented

1. Whether the representative claims of the '187 and '005 patents are directed to patent-ineligible abstract ideas under 35 U.S.C. § 101.
2. Whether the representative claims of the '187 and '005 patents contain an inventive concept sufficient to transform the abstract ideas into patent-eligible applications under Alice step two.
3. Whether the representative claims of the '622 and '686 patents are directed to patent-ineligible abstract ideas.
4. Whether the representative claims of the '622 and '686 patents contain an inventive concept under Alice step two.
5. Whether the district court erred by deciding eligibility on the pleadings after adopting proposed claim constructions and by excluding materials concerning novelty and nonobviousness.

Disposition

affirmed