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Customedia Techs., LLC v. Dish Network Corp. (Fed. Cir. Mar. 6, 2020)

The Federal Circuit affirmed the Patent Trial and Appeal Board's determination that claims directed to data management and processing systems for merely storing advertising data are patent ineligible under 35 U.S.C. 101 as part of a Covered Business Method review of the patents.

With regard to Alice step one, Customedia asserted that the claimed invention improves the functionality of the computer itself. The court rejected this argument stating "by dedicating a section of the computer’s memory to advertising data, the claimed invention ensures memory is available for at least some advertising data. This does not, however, improve the functionality of the computer itself. Even if we accept Customedia’s assertions, the claimed invention merely improves the abstract concept of delivering targeted advertising using a computer only as a tool."

"We have also held that improving a user’s experience while using a computer application is not, without more, sufficient to render the claims directed to an improvement in computer functionality."

"The only improvements identified in the specification are generic speed and efficiency improvements inherent in applying the use of a computer to any task... This is not an improvement in the functioning of the computer itself."

With regard to Alice step two, the court explained that there are no additional elements that transform the nature of the concept into a patent-eligible application because "the claims recite only generic computer components, including a programmable receiver unit, a storage device, a remote server and a processor" and "[t]he specification acknowledges that the storage device “may be any storage device for audio/video information known in the art” and the receiver unit may include “any digital or analog signal receiver and/or transmitter capable of accepting a signal transmitting any kind of digital or broadcast information."

Read the case here.

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