"GoTV sued Netflix in 2022 and Netflix moved for judgment on the pleadings that the claims of all three patents claim patent-ineligible subject matter. GoTV opposed and also suggested the court convert the motion to one for summary judgment. The district court ultimately denied Netflix's motion, finding that the claims were not directed to ineligible subject matter at Alice step one."
"However, in its claim constructions, the district court agreed with Netflix that "a phrase common to all claims of the '865 patent-'discrete low level rendering command'-is indefinite" and therefore held all of the claims invalid as indefinite under 35 U.S.C. § 112(b). GoTV made a number of arguments on appeal and Netflix cross-appealed the district court's Section 101 ruling. Since the cross-appeal issue was dispositiv"
The Federal Circuit partially reversed the Central District of California's decision and found GoTV's patents invalid under 35 U.S.C. § 101 as directed to an abstract idea. The panel reversed the district court's finding that claim language was indefinite, but concluded the claimed combination of collecting and combining information for presentation lacked a focus on a non-abstract technological advance. The court vacated the district court's summary judgment of no inducement and its denial of GoTV's new-trial damages motion, ordered entry of judgment for Netflix, and thus ended the case. The patents at issue are titled "Server Method and System for Rendering Content on a Wireless Device."
Read at IPWatchdog.com | Patents & Intellectual Property Law
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