Intellectual Ventures I LLC v. Symantec Corp., No. 15-1769 (Fed. Cir. 2016)
Annotate this CaseIV owns the 050 patent entitled, “Distributed Content Identification System,” directed to methods of screening emails and other data files for unwanted content; the 142 patent, entitled, “Automated Post Office Based Rule Analysis of E-Mail Messages and Other Data Objects for Controlled Distribution in Network Environments;” and the 610 patent, entitled, “Computer Virus Screening Methods and Systems.” IV sued two developers of anti-malware and anti-spam software for infringement. A jury found that the asserted claims were not invalid under 35 U.S.C. 102 and 103 and that certain claims were infringed. After trial, the court held that the asserted claims of the 050 and 142 patents were patent-ineligible under 35 U.S.C. 101, but that the asserted claim of the 610 patent was eligible. The Federal Circuit affirmed as to the 050 and 142 patents, stating that “each step does no more than require a generic computer to perform generic computer functions.” The court reversed as to the 610 patent, which is “not directed to a specific improvement to computer functionality,” but to the use of conventional or generic technology in a nascent but well-known environment.
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