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ARTICLE · 16 DECEMBER 2016

Federal Circuit Finds Another Software Patent Ineligible

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In Affinity Labs of Texas, LLC v. Amazon.com, Inc., Chief Judge Prost affirmed a district court's finding that Affinity Labs' patent was invalid for being directed to ineligible subject matter...

United StatesIntellectual Property

In Affinity Labs of Texas, LLC v. Amazon.com, Inc., Chief Judge Prost affirmed a district court's finding that Affinity Labs' patent was invalid for being directed to ineligible subject matter because it was directed to an abstract idea and contained no inventive concept. Affinity's U.S. Patent No. 8,688,085 is directed to media systems that deliver content to a handheld wireless electronic device. The court went through the two step process articulated in Alice to determine the patent's eligibility under § 101.

The court found that Claim 14 is representative and is directed to a network-based media system with a customized user interface, in which the system delivers streaming content from a network-based resource upon demand to a handheld wireless electronic device having a graphical user interface. Affinity asserted this patent against Amazon's music system, which allows customers to stream music from a customized library.

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