Data Scape Limited sued Western Digital in the U.S. District
Court for the Central District of California, alleging infringement
of four patents that claim methods, systems and apparatuses for
transferring music from one device to another device. The district
court dismissed the complaint with prejudice, finding that the
claims of the asserted patents were invalid under Section 101.
Following the dismissal, Data Scape moved to alter the judgment
to allow Data Scape to file an amended complaint. The district
court denied that motion.
Alice Step One
The asserted patents describe the "cumbersome"
problem, when seeking to transfer several songs from a server to a
device, of selecting pieces of music to be transferred piece by
piece. In order to solve the problem, "a list of selected
pieces of music from the musical data stored in the music server is
created and the selected musical data on the list is transferred in
a batch operation."
