TQP Development, LLC v. Intuit Inc.
Addressing an argument that a data-encryption patent was
directed to non-eligible subject matter because it covered an
abstract idea divorced from a particular machine, Judge William
Bryson, sitting by designation in the U.S. District Court for the
Eastern District of Texas, denied defendants' summary judgment
motion on § 101, finding that the plaintiff's "device
agnostic" data-encryption patent was directed toward
patentable subject matter despite failing to recite a particular
machine, such as a computer, and despite the fact that the patent
"merely" transformed data from one form to
another—which often is not considered a
"transformation" under the machine-or-transformation
test. TQP Development, LLC v. Intuit Inc., No.
2:12-cv-180-WCB (E.D. Tex. Feb. 19, 2014) (Bryson, J.).
