Two-Way Media Ltd v. Comcast Cable Communs., LLC
United States Court of Appeals for the Federal Circuit
November 1, 2017, Decided
[*1332] [***1522] Two-Way Media Ltd. appeals from a decision of the United States District Court for the District of Delaware that found the claims of the asserted patents to be directed to patent ineligible [**2] subject matter under 35 U.S.C. § 101. Because the claims are directed to abstract ideas and contain no additional elements that transform the nature of the claims into a patent-eligible application of the abstract ideas, we affirm.
A. Technical Background
The patents-in-suit are related as a series of continuation applications, and thus share substantially the same specification. U.S. Patent No. 5,778,187 ("'187 patent") issued first, followed by U.S. Patent Nos. 5,983,005 ("'005 patent"), then 6,119,163 [*1333] (not at issue here), then 6,434,622 ("'622 patent"), and then 7,266,686 ("'686 patent"). The patents are entitled "Multicasting Method and Apparatus," and generally relate to a system for streaming audio/visual data over a communications system like the internet. Claim 1 of the '187 patent is representative of all claims of the '187 patent and '005 patent, claims 1 and 29 of the '622 patent, and claims 1, 22, 26, and 30 of the '686 patent are representative of their respective patents.
The patents explain that internet systems typically operate on a point-to-point, or unicast, basis. In unicast systems, a message is converted into a series of addressed packets which are routed from a source node to a destination node. But these unicast systems lack the capability to broadcast a message from a source node to all the other recipients in a network, [**3] as this type of operation could easily overload the network.
IP Multicasting, in contrast, provides a way to transmit one packet of information to multiple recipients. In such a system, packets destined for several recipients are encapsulated in a unicast packet and forwarded from a source to a point in a network where the packets are replicated and forwarded on to all desired recipients. A multicast packet can be routed from a source node through a plurality of multicast routers to one or more devices receiving the multicast packets. The packet can then be distributed to all the host computers that are members of the multicast group. The patents explain that this technology had previously [***1523] been used to provide internet-based audio/visual conferencing servicing as well as radio-like broadcasts to interested parties.Read The Full CaseNot a Lexis Advance subscriber? Try it out for free.
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874 F.3d 1329 *; 2017 U.S. App. LEXIS 21706 **; 124 U.S.P.Q.2D (BNA) 1521 ***; 2017 WL 4931936
TWO-WAY MEDIA LTD., Plaintiff-Appellant v. COMCAST CABLE COMMUNICATIONS, LLC, COMCAST INTERACTIVE MEDIA LLC, VERIZON SERVICES CORP., VERIZON ONLINE LLC, Defendants-Appellees
Subsequent History: US Supreme Court certiorari denied by Two-Way Media v. Comcast Cable, 2018 U.S. LEXIS 6126 (U.S., Oct. 15, 2018)
Prior History: [**1] Appeals from the United States District Court for the District of Delaware in Nos. 1:14-cv-01006-RGA, 1:14-cv-01212-RGA, Judge Richard G. Andrews.
Two-Way Media Ltd. v. Comcast Cable Communs., LLC, 2016 U.S. Dist. LEXIS 107478 (D. Del., Aug. 15, 2016)
Media, abstract idea, district court, user, stream, patent, inventive, packets, real-time, network, recite, monitoring, delivery, eligible, architecture, routing, ineligible, constructions, forwarding, Servers, records, visual, conventional, intermediate, generic, signals, subject matter, specification, multicast, argues
Civil Procedure, Judgments, Pretrial Judgments, Judgment on Pleadings, Patent Law, Jurisdiction & Review, Standards of Review, De Novo Review, Subject Matter, Subject Matter, Utility Patents, Utility Patents, Process Patents, Computer Software & Mental Steps, Anticipation & Novelty