Computer-Based Publishing Patent Goes Offline After Alice Inquiry

In a recent order from the District of Massachusetts, the court granted a defendant's motion for summary judgment in a patent infringement dispute, finding the asserted patent claims invalid under 35 U.S.C. § 101. The court's underlying analysis is particularly instructive for its application of the Alice two-part framework to claims that are directed to computerized systems and methods for secure data sharing on the Internet.

The patent at issue – U.S. Patent No. 6,253,216 ("the '216 Patent") – claims a method and apparatus for providing users with a secure way to display personal information to computer network users. According to the '216 Patent, the shortcomings of existing computer systems in this regard include: requiring that users be capable of generating their own web pages using a programming language or other protocol; providing no privacy to users because of the world-wide access that the Internet allows; and struggling to direct a desired audience to a