Judge Donato Rule 12(c) motion
granted; five patents found invalid for claiming an
abstract concept: "the unremarkable concept of people working
together on a project." Open Text S.A. v. Box, Inc. et al.
Case No. 13-cv-04910-JD
Open Text S.A. is the Luxembourg subsidiary of Canadian
"Enterprise Information Management" provider Open Text
Corp. "Enterprise Information Management" is, generally,
the capability to store, share, and classify documents and
information, to provide version control and may include enterprise
collaboration tools. Open Text filed originally filed suit against
Box. Inc. and Carahsoft Technology Corp., alleging infringement of
a dozen patents in the Eastern District of Virginia. The case was
subsequently transferred to the Northern District, where Box is
headquartered, and, last week, Judge Donato granted Box's Rule
12(c) motion on the pleadings, ruling that five of these patents,
all sharing a common specification, are invalid under 35 U.S.C.
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