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ARTICLE · 02 NOVEMBER 2015

Access To Continued Litigation Denied: Method For Intrusion Detection Found Invalid Under Section 101

Order Granting Motion for Judgment on the Pleadings, Protegrity USA, Inc., et al. v. Netskope Inc., Case No. 15-cv-02515-YGR (Judge Yvonne Gonzalez Rogers)

United StatesIntellectual Property

Order Granting Motion for Judgment on the Pleadings, Protegrity USA, Inc., et al. v. Netskope Inc., Case No. 15-cv-02515-YGR (Judge Yvonne Gonzalez Rogers)

The NorCal IP Blog has extensively covered the increasing popularity of 35 U.S.C. §101 motions post-Alice, most recently here. In Protegrity, Judge Rogers continued the trend of increased judicial scrutiny of software patents in granting Netskope's motion for judgment on the pleadings under FRCP 12(c). Judge Rogers granted the motion without the benefit of Markman proceedings or substantial discovery, just eight months after Protegrity filed its complaint.

Protegrity accused Netskope of infringing a single patent, U.S. Patent No. 7,305,707 ("the '707 Patent"), entitled "Method for Intrusion Detection in a Database System." The claims are directed to the use of intrusion detection policies to manage user access to a particular database. For example, a policy could be applied to limit the amount of information a

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