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ARTICLE · 01 JULY 2020

Federal Circuit: Purported Technological Solution Must Be Claimed To Survive A Section 101 Inquiry

Dropbox and its subsidiary asserted three patents against Synchronoss Technologies related to "Secure Delivery of Information in a Network," "File Upload Synchronization"...

United StatesIntellectual Property

The U.S. District Court for the Northern District of California agreed with Synchronoss. Dropbox appealed, and the U.S. Court of Appeals for the Federal Circuit addressed all three patents in turn.

Patent 1: Secure Delivery of Information in a Network

For the Secure Delivery patent, the federal circuit agreed with the district court that the representative claim was directed to "(1) associating a security level with a data resource, (2) associating a security level with a mode of identification of a user, and then (3) ensuring that the user's security level is sufficiently high to meet the security level of the data resource to access the data resource." This constituted an abstract idea. Both courts agreed that the claim did not provide any limits that curb how the apparatus performed the functions and, instead, invoked computers to execute data access control principles.

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