The court however denied Motorola’s motion with respect to IV’s patent directed at contentbased allocation of network bandwidth and system resources. The court agreed that such resource allocation was an abstract idea but found that the claims tied the method to a wireless network over which the base station connected to customer computers. IV’s expert had opined that the invention “schedules the flow of information on the network according to the claimed method as opposed to how it would otherwise proceed.” This, the court held, is “necessarily rooted in computer technology and solves a problem specifically arising in the realm of computer networks.” The court reasoned the claims were directed to the “inventive concept” of using packet headers to allocate bandwidth, even though they did not recite implementation details such as how the packet headers would be used to accomplish the allocation. The court pointed to the dependent claims as providing additional specificity on packetcentric protocols and packet types to be used with the invention. The court concluded that because the claims specified “how interactions with the network are manipulated to yield a desired result,” they were directed to patenteligible subject matter under Alice, and the more recent federal circuit decision in DDR Holdings .
Intellectual Ventures I LLC et al v. Motorola Mobility LLC, No. 111cv00908 (DED Feb. 24, 2015) (Robinson, J.).