SAN FRANCISCO – The U.S. District Court for the Northern District of California has granted the defendant's motion to dismiss a copyright infringement dispute between two cloud business companies.
Ruling against plaintiff RingCentral Inc. on March. 8, the court said the company’s four patent infringement accusations against defendant Dialpad Inc. are invalid but granted leave to amend.
"Although the court doubts whether the identified deficiencies can be cured by amendment, the court will nonetheless grant leave to amend solely to allow RingCentral an opportunity to attempt to plead patent eligibility," Judge Jon S. Tigar wrote in the opinion.
According to the opinion, RingCentral Inc. and Dialpad Inc. are "competitors in the 'cloud-based unified communications' market, both offering voice, video and messaging services."
The court said RingCentral filed the lawsuit alleging that Dialpad’s products infringe on its patents.
The court didn’t agree with RingCentral, which argued that the patents are valid because they use “unconventional techniques.”
According to the opinion, RingCentral’s complaint does not allege “'specific' facts 'suggesting that the claimed invention is directed to an improvement in the computer technology itself and not directed to generic components performing conventional activities.'”
“The 'unconventional' allegations are conclusory and the court need not accept them as true,” the opinion stated.
The court said RingCentral’s complaint includes the '367 patent, a system which allows messages to be routed over the Internet according to custom routing rules.
“The claimed system uses a ‘message management server’ to distribute messages, according to distribution rules, among members of the same department or between the department and an outside user,” the opinion stated.
According to the opinion, RingCentral didn’t show anything “in the claims or specification of the ’367 patent that supports its assertions that its identified problem is new to virtual PBX (private branch exchange) systems, or that its claimed arrangement of elements yields any specific technical improvements over the prior art and it is to that language that courts must look to determine whether the patent ‘constitutes a concrete implementation of the abstract idea in the form of an inventive concept,” the opinion stated. “...The claim does not contain an inventive concept sufficient to render it patent eligible.”
The court also struck down RingCentral’s argument for the '496 patent, a system which provides a main number and allows calls made to the main number to be managed according to one or more sets of call rules.
“For example, when an outside caller calls the virtual PBX main number for a small business, and chooses an extension, the extension user associated with that extension can be reached on a predefined mobile device, home telephone, office phone or other phone type according to the call handling rules,” the opinion stated.
According to the opinion, the system provides forwarding of calls to different numbers based on the time of day the calls are received.
“As with the ’367 patent, RingCentral does not contend that the elements at issue in the ’496 patent – virtual PBX systems and user interfaces – are inventive,” the opinion stated. “Instead, it argues that the patent survives step two because of its ‘non-conventional and non-generic arrangement of known, conventional pieces.’”
The court also ruled against the claims of infringement of the '669 and '363 patents, which allow a user to send and retrieve voice, fax, email and text messages from a "single interface such as a phone, fax machine or a personal computer,” according to the opinion.
“Without any specific improvement to existing technological processes, all of these asserted limitations ‘are themselves abstract,’ they are therefore not inventive,” the opinion stated.