Summary
This memorandum opinion and order addresses Defendant Cisco Systems, Inc.'s motion to dismiss for failure to state a claim under Federal Rule of Civil Procedure 12(c). The court evaluates whether the asserted patent claims are directed to patent-ineligible abstract ideas under the Alice/Mayo framework. Applying Federal Circuit precedent, the court concludes that the claims recite a specific improvement to computer network functionality and congestion control rather than an abstract idea. Consequently, the court denies Cisco's motion to dismiss.
Topics
Practice areas
Questions Presented
- Whether the asserted claims of the ’372 Patent are directed to patent‑ineligible subject matter under 35 U.S.C. §101.
Holdings
- The court held that the claims are directed to a specific improvement in computer‑network functioning and therefore are patent‑eligible; the motion to dismiss is denied.
Key quotations
“Accordingly, the claims are not directed to an abstract idea, and Cisco has failed to prove by clear and convincing evidence that the claims are invalid under Section 101.” (at 13)
Factual background
SVC holds patents covering a congestion‑control system that uses an overlay network and packet‑prioritization layering to improve multicasting of video streams. Cisco is accused of infringing claims 1, 6, and 11 of that patent by delivering layered video data over the Internet.
Procedural history
Scale Video Coding LLC sued Cisco for infringement of U.S. Patent No. 11,019,372. Cisco filed a Rule 12(c) motion to dismiss alleging lack of patent‑eligible subject matter. The motion was fully briefed and heard, and the court denied the motion.