PersonalWeb Technologies LLC v. Google LLC, No. 20-1543 (Fed. Cir. 2021)
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PersonalWeb’s asserted patents claim priority from an application filed in 1995 and relate to data-processing systems that assign each data item a substantially unique name that depends on the item’s content. These content-based identifiers are generated by a mathematical algorithm, such as a cryptographic hash or “message digest” function. The identifier changes when the data item’s content changes.
PersonalWeb sued Google for patent infringement. The court stayed the cases pending resolution of several inter partes reviews (IPRs); the Patent Trial and Appeal Board found all challenged claims unpatentable, concluding that using hash-based identifiers for data management was disclosed in the prior art. The Federal Circuit affirmed. After the stay was lifted, the district court granted Google judgment on the pleadings, citing 35 U.S.C. 101. The Federal Circuit affirmed. the claims focus on “mere automation of manual processes using generic computers.” “lie[] entirely in the realm of abstract ideas, with no plausibly alleged innovation in the non-abstract application realm.”
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