Plaintiff PersonalWeb Technologies lost a series of data storage patent suit against prominent web companies in decisions delivered on January 29. Across the three cases, the court granted motions for judgment on the pleadings in favor of the defendants in cases brought against EMC Corporation, Google, and Facebook. The court’s decision, which invalidated the patent claims, was a clear victory for EMC, Google, and Facebook as well as a slew of other tech companies sued by PersonalWeb. The suits were filed in the California Northern District Court.
PersonalWeb’s suits against EMC Corporation, Google and Facebook originated in 2013, when they were transferred to California from Texas. PersonalWeb owns patents “that claim methods for reliably identifying, locating, and processing data in a computer network,” known as the True Name patents. PersonalWeb’s patents work to fix data storage problems on larger networks; they “developed a system that replaces conventional file names with unique content-based identifiers.”
In their countering Motion for Judgment on the Pleadings, the defendants likened PersonalWeb’s purported patents to the Dewey Decimal System to demonstrate their unpatentability. The defendants asked the court to decide if the claims are protected by Section 101, which determines if patentable items are “any new and useful process, machine, manufacture, or composition of matter, or any new and useful improvement thereof.” The defendants argued that these patents are not patentable because they do not offer anything new. Additionally, in prior rulings, the Patent Trial and Appeal Board had concluded that many claims made by the patents were invalid.
The court held that PersonalWeb’s remaining patent claims did not meet the standard of patentability articulated in 35 U.S.C. Sec. 101, which states that patentable inventions must demonstrate “any new and useful process, machine, manufacture, or composition of matter, or any new and useful improvement thereof.” The judge held that the PersonalWeb patents “are all directed to the same abstract three-step process.”
PersonalWeb filed these broad-sweeping patent infringement suits in the patent-lawsuit friendly Eastern District of Texas; the suits were later transferred to California, which upheld the PTAB’s decision. The three suits resolved in the Northern District of California were only a part of the eight suits that PersonalWeb filed regarding the same patents.