By Memorandum Opinion entered by The Honorable Richard G. Andrews in Comcast IP Holdings I, LLC v. Sprint Communications Company L.P., Civil Action No. 12-205-RGA (D.Del., July 16, 2014), the Court granted defendant Sprint’s Motion for Partial Summary Judgment that the Asserted Claims of U.S. Patent No. 6,873,694 (“the ‘694 patent”) are Invalid Under 35 U.S.C. § 101. Specifically, the Court concluded that Claim 21, the only asserted claim of the ‘694 patent, is drawn to an abstract idea and its two steps describe the simple concept of determining if a decision is required. Id. at 4-6. The Court recognized that a decision is a “basic tool of scientific and technological work” and, thus, is a patent ineligible abstract idea. Id. at 7. After analyzing the additional limitations imposed by Claim 21, the Court also concluded that “the idea of a decision has not been sufficiently limited by the claim to prevent the claim from ‘cover[ing] the full abstract idea itself.’” Id. at 7.
A copy of the Memorandum Opinion is attached.