“The court found that the patent claims were directed to ‘the abstract idea of remotely updating the content of a user device.'”
On January 24, the United States District Court for the Southern District of New York ruled that EscapeX IP LLC’s US Patent No. 9,009,113 was disqualified as directed to an abstract idea. The patent covers a process that allows users to upload “dynamic albums” and save them to their device. The district court granted Block, Inc. (better known as music streaming platform Tidal)’s motion to dismiss the patent infringement action pursuant to Rule 12(b)(6) of the Federal Rules of Civil Procedure.
In the district court’s opinion, the patent specification states: It’s a disconnect between the streaming service and the artist’s social media pages. Of the 30 claims associated with the ‘113 patent, the most relevant to this litigation is independent claim 27, which states, “For receiving instructions from artists to update dynamic albums stored on user devices. It claims a “computer-executed method” of EscapeX alleged that Block infringed its patent through generating song mixes that were curated for each user and changed based on user activity.
In its discussion, the court determined that the patent claims were directed to “the abstract idea of remotely updating content on a user device.”so Alice In step 1, the district court ruled that the claim: Affinity Labs of Tex., LLC v. Amazon.com Inc., “The ‘113 patent goes one step beyond the Affinity Labs patent: by allowing artists to control the media content that is presented to user devices, rather than leaving that control to the user.” , nevertheless, the Federal Circuit has repeatedly held that “claims reciting the collection, transfer, and disclosure of data are directed to an abstract idea,” and therefore that “this additional feature is not intended for Alice’s ‘113 We decided not to save Step 1 of the patent.” ”, and we believe that “the broad concept of communicating information wirelessly” is an abstract idea. Unlike the patent at issue in Uniloc USA, Inc. vs. LG Electronics USA, Inc.. Also DDR Holdings, LLC v. Hotels.com, LP., the patent simply “instructs a person”
It states that a computing system sends instructions to another device, which then implements those instructions, and ultimately “uses a common computing device in a traditional way.” There is only one,” the court said.
so Alice In Step 2, the court rejected EscapeX’s argument that “providing artist control of dynamic albums on a user’s device” was previously impossible and therefore constitutes an inventive concept.The court said the claimed inventive concept was “merely instructions for implementing an abstract idea on a computer.” ChargePoint, Inc. vs. SemaConnect, Inc.The court ruled that the Federal Circuit’s use of the abstract idea of ”network control” to solve the problem “without improving the functionality of the charging station” made the claims eligible for patent protection. He pointed out that he had dismissed a similar allegation that it had become.
The court did not grant EscapeX permission to amend because it said the claims matter was material and “an amendment would be futile.”
