Mobile Device Data Monitoring Patent Not Directed to Abstract Idea Under § 101

Defendant, Zoho Corp., filed a summary judgment motion, arguing that the ’740 Patent was invalid under § 101, because it was directed to an abstract idea and fails to disclose any technological advance. Specifically, Zoho argued that the ’740 Patent claims are directed to “the disembodied idea of using symbols on a display to represent external information and updating these symbols as that information changes.”

Plaintiff countered that at the time the ’740 Patent was issued, the growth of mobile device usage led to a corresponding increase in the demand for rich information content; however, the inevitable space constraints on mobile devices “limit[ed] the richness of information content available to a user.” The ’740 Patent, as plaintiff argues, had “the specific technical objective of allowing status updates to be displayed more efficiently within the limited display screen of a mobile phone, pager, PDA or similar mobile device.”

In his holding, Judge Sparks held (without reasoning) that the ’740 Patent “does not embody an impermissibly abstract idea. Therefore, the court need not determine whether the claims contained an inventive concept sufficient to transform the allegedly abstract idea into patent-eligible subject matter.”

Versata Software, Inc. et al v. Zoho Corp., 1-13-cv-00371 (W.D. Tex. October 26, 2015, Order) (Sparks, J.).