FREE STREAM MEDIA CORP. v. ALPHONSO INC.

FREE STREAM MEDIA CORP. v. ALPHONSO INC., Appeal Nos. 2019-1506, 2019-2133 (Fed. Cir. May 11, 2021).  Before Dyk, Reyna, and Hughes.  Appealed from N.D. Cal. (Judge Seeborg). (Patent Eligibility)

Background:

Free Stream Media (d.b.a. Samba) sued Alphonso for infringing its patent claims related to a system providing a mobile phone user with targeted information (i.e., advertisements) that is determined to be relevant to the user based on data gathered from the user’s television.  Alphonso filed a motion to dismiss on grounds that the asserted claims are directed to patent-ineligible subject matter under § 101.

The California district court denied the motion to dismiss and concluded that the asserted claims are not directed to an abstract idea of tailored advertising as argued by Alphonso.  The claims of Samba’s patent generally utilize three main components: (1) a networked device (e.g., a smart TV); (2) a client device (e.g., a mobile device); and (3) a relevancy matching server.  The claims recite that the client device is “sandboxed,” and Samba’s patent explains that (i) sandboxing is a security measure for preventing applications from accessing data of other applications and (ii) communication between the networked device and the client device is established by bypassing the sandbox without intervention from the user.  Based on this description, the district court determined that the claims of Samba’s patent are directed to “systems and methods for addressing barriers to certain types of information exchanged between various technological devices.”  In other words, the district court found that the claims were directed to patent-eligible subject matter under Step 1 of the Alice analysis.  Alphonso appealed.

Issue/Holding:

Did the district court err in finding that the claims of Samba’s patent are directed to patent-eligible subject matter? (continue reading)

Summary byGary Koo

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