Free Stream Media Corp. v. Alphonso Inc., No. 19-1506 (Fed. Cir. 2021)
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Samba asserted infringement of its 668 patent in the Northern District of California. In the Eastern District of Texas, Samba asserted its 356 patent, entitled “Targeting with Television Audience Data Across Multiple Screens,” relating to a system providing a mobile phone user with targeted advertisements, deemed relevant to the user based on data gathered from the user’s television. Both cases were consolidated in the Northern District of California. The Texas court had already construed a disputed term for both patents. The California court adopted that claim construction; Samba stipulated to noninfringement as to the 668 patent.
Defendant moved to dismiss on grounds that the asserted claims of the 356 patent are patent-ineligible subject matter under 35 U.S.C. 101. The court denied the motion, finding that the 356 patent “describes systems and methods for addressing barriers to certain types of information exchange between various technological devices, e.g., a television and a smartphone or tablet being used in the same place at the same time.” The court subsequently entered summary judgment of noninfringement.
The Federal Circuit reversed the denial of the motion to dismiss, did not reach the issue of infringement, and affirmed the claim construction. Samba’s asserted claims are not directed to an improvement of technology or creation of new computer functionality but are directed to an abstract idea; the claims comprise generic computing components arranged in a conventional manner. Samba’s desired claim construction, covering one-way communication, contradicts the specification.
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