Selecting Compression Format in Streaming Digital Video Held Not Patent-Eligible: Adaptive Streaming Inc. v. Netflix, Inc.
Patent claims directed to distributing streaming video data in a first formal and then converting the data to a second format are not patent-eligible, said the court in Adaptive Streaming Inc. v. Netflix, Inc., Case No. SA CV 19-1450-DOC (KESx) (C.D. Cal. Nov. 19. 2019). The court thus granted the defendant’s Rule 12(b)(6) motion to dismiss, holding claims of U.S. Patent No. 7,047,305 (“Personal broadcasting system for audio and video data using a wide area network”) invalid under 35 U.S.C. § 101. One lesson of this case is that even long claims with a lot of technical verbiage should not necessarily be expected to survive an Alice challenge. Here is independent claim 39 from the ’305 patent, discussed in the court’s opinion; the bolded limitations are those that the plaintiff argued, without success, represented a patent-eligible technical innovation: A system to broadcast to at least one client device, the system comprising: a processor; and a broadcasting server coupled to the processor, the broadcasting server including: an image retrieval portion to retrieve at least one incoming video signal having a first format; a data structure usable to determine parameters for second compression formats for the at least one incoming video signal;… Read More »Selecting Compression Format in Streaming Digital Video Held Not Patent-Eligible: Adaptive Streaming Inc. v. Netflix, Inc.