"US Patent No. 7,679,637 (the '637 patent) covered a web conferencing system with "time-shifting capabilities," whereby a participant could watch a web conference a) in real time, b) with a delay while still in progress, or c) after the web conference had concluded. Participants could also adjust the playback speed of the web conference, and simultaneously view multiple data streams, such as video, shared documents, websites, and chat."
"Under Alice Step One, the Court found that the claims of the '637 patent were directed to the abstract idea of "allowing asynchronous review of presentations" as a live web conference progresses, rather than reciting a specific technological advancement. The Court emphasized that the claims merely describe the results - what the system does - rather than how those results are achieved in a technical manner."
Federal Circuit affirmed dismissal of an infringement complaint against Google for U.S. Patent No. 7,679,637. The patent described time-shifting capabilities allowing participants to view web conferences live, delayed while in progress, or after conclusion, adjust playback speed, and view multiple data streams concurrently. The court applied the Alice two-step test. At step one, the claims were characterized as an abstract idea: allowing asynchronous review of presentations during a live web conference. The court determined the claims recited result-oriented functionality without specifying technical improvements. The claims lacked an inventive concept and were held patent ineligible under 35 U.S.C. §101.
Read at Global IP & Technology Law Blog
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