Northern California Record

Friday, November 15, 2019

Court dismisses patent infringement case against

By Russell Boniface | Oct 8, 2016


SAN FRANCISCO -- The U.S. District Court for the Northern District of California has dismissed a suit against by Tridim Innovations alleging patent infringement.

Tridim filed suit against for two patents on a "computer controlled display system” it obtained by Xerox Corp. uses a similar software for its Kindle Fire.

The patent in question described a three-dimensional computer document workspace that allows users to organize large numbers of documents by touching, dropping or flicking them into three separate spaces based on whether the files are in use. The patent analogized the three spaces to a desk, a space behind a desk and a bookshelf.

Amazon argued that the patents are invalid under section 101 as applied in the Alice Corp. Pty. Ltd v. CLS Bank Int'l in 2014. In Alice, the Supreme Court articulated that for a computer-related claim to be patent eligible, it must be “significantly more” than an abstract idea and be an “inventive concept.”

Tridim contented that dividing its computer display into three spaces confines their invention to a specific system, and therefore it is not an abstract idea.

Judge James Donato found the patents invalid under Alice because they were based on the abstract ideas of retrieving and arranging documents. Donato ruled Tridim did not demonstrate an inventive concept. The judge noted that storing documents is a basic concept of organization and is “common solution to a common problem.” The ruling came days before the patents were set to expire on Sept. 26.

“The court said the idea of organizing your office is an abstract idea,” professor Robin Feldman, director of the Institute for Innovation Law, Hastings College of Law, at the University of California, told the Northern California Record. “You cannot patent an abstract idea. There was no inventive concept. Even Tridim analogized their invention to the space behind a desk and a bookshelf.”

The court also found that Tridim patents do not require any special software or hardware of any type to make their computer display any more than commonplace, specifically a lack of technology that would allow a user to move and position files within a 3-D system.

The District Court also found that despite the use of the word “circuitry” in the patents, no actual circuity is disclosed. 

“The court pointed out that the patent holder used the term circuitry over and over again in the patents, but the invention didn’t have anything to do with computer circuitry,” Feldman said. “Just because you use clever words doesn’t mean there is an underlying invention.”

Feldman says the lawsuit brought by Tridim against is an example of a patent troll case. 

“This type of patent has been a favorite weapon for patent trolls,” she said. “The Supreme Court slammed the door on this type of activity in the Alice case. Now we are seeing the fallout in the lower courts.”

Feldman said that the Supreme Court puts abstract ideas with natural phenomenon, products of nature and formulas as non-patentable.

“An entire generation of software patent cases were largely based on abstract ideas,” Feldman said. “These were perfect weapons to launch at product companies because they were incredibly broad.”

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