Motion To Dismiss For Failure To Claim Patent-Eligible Subject Matter Is Granted In Part

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Pragmatus Telecom, LLC v. Genesys Telecommunications Laboratories, Inc., et al., C.A. No. 14-26 - RGA, July 9, 2015

Andrews, J. Defendants’ motion to dismiss amended complaints for failure to claim patent-eligible subject matter pursuant to § 101 is granted in part. The court heard oral argument and considered plaintiff’s proposed claim constructions it urged the court to focus on for this motion.  The court also received letters from both parties relating to background information regarding the history of call centers.

The disputed technology relates to controlling communications between customers and organizations using certain computer systems.  Plaintiff asserts that defendants infringe four patents, continuations from a single patent which share a common specification.  The court restricts its decision to the claims asserted in the ‘314 patent and declines to dismiss claims from other patents since defendants have not shown that the ‘314 patent claims are representative of the asserted claims from the other patents.  The court finds that the claims are directed to the abstract idea of connecting customers to call centers. Additionally, there is no inventive concept under Alice.

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