Useful Improvement To Computer Network Using Standard Equipment Held Patent Eligible

In Cooperative Entertainment, Inc. v. Kollective Technology, Inc.,¹ the Federal Circuit held that useful improvements to computer networks can be patent eligible even when standard computing equipment is used. In addition, assertions by a patent owner in a complaint that the inventive concept included a specific network structure for sharing content through a dynamic peer-to-peer (P2P) network were sufficient to prevent dismissal of the case for lack of patent eligibility.

Cooperative Entertainment, Inc. (Cooperative) owned U.S. Patent No. 9,432,452 ('452 patent), directed to configuring a peer-to-peer (P2P) dynamic network for transmitting large files, such as videos and video games, where the distribution of content is performed outside of content distribution networks (CDNs), i.e., outside of a static network of controlled systems. Dynamic P2P networks with peer nodes that process the same content concurrently were used to send the content to each other as an