Patent Claims Are Not Drawn to Patent Eligible Subject Matter

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Novo Transforma Technologies, LLC v. Sprint Spectrum L.P., et al., C.A. Nos 14-612 – RGA; Novo Transforma Technologies, LLC v. T-Mobile US, Inc., C.A. No 14-613 – RGA; Novo Transforma Technologies, LLC v. Tracfone Wireless, Inc., C.A. No 14-614 – RGA; Novo Transforma Technologies, LLC v. United States Cellular Corporation, C.A. No 14-615 – RGA; Novo Transforma Technologies, LLC v. Cellco Partnership d/b/a Verizon Wireless, C.A. No 14-616 – RGA, September 2, 2015.

Andrews, J.  Motion for judgment on the pleadings.  Defendants’ motion for invalidity under § 101 is granted.

The defendants filed a motion for judgment on the pleadings for invalidity under § 101.  The motion was granted.  The plaintiff’s claim construction was adopted for purposes of the motion.  The Court then applied the two-step Alice framework and found that plaintiff’s U.S. Patent No. 5,826,034 claims the abstract idea of “translation” and does not solve a problem specific to the realm of computer networks.  The additional limitations in the claims do not amount to an “inventive concept.”  The “at different locations” element is not unique to telecommunication electronic devices and the other limitations are nothing more than well-understood, conventional activities previously known in the industry.

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