Delaware District Court: Electronic Maps are Still Patent Eligible

Jason Bourgeois

IP Portfolio Manager

Contact: jason@ipval.com

On April 28th in the U.S. District Court for the District of Delaware, Judge Andrews denied Google’s 101 motion for summary judgment. The motion asserted that ART+COM Innovationpool’s geographical data display patent (RE44550 Method and device for pictorial representation of space-related data; Claim 1 of the ‘550 patent was the basis of the Court’s review and is reproduced below) was invalid for lack of patentable subject matter. The Court found that the asserted claims did not lack an inventive concept. (ART+COM Innovationpool GmbH v. Google Inc., 1-14-cv-00217)

First, the Court characterized the nature of the patent. The patent at issue “enable[s] [space related] data to be represented in any preselected image resolution in the way in which the object would have been seen by an observer with a selectable location and selectable direction of view.” The patent is directed to “keep[ing] the effort required for generating an image so low that the image generation takes place so rapidly that upon alteration of the location and/or of the direction of view of the observer, the impression of continuous movement about the object arises.”

The Court next noted that the patent is squarely placed as an improvement over prior art, stating that “these goals, the patent explains, are improvements over prior art systems like electronic maps stored on CD-ROMs, car navigation systems, or flight simulators.” The Court went on to note that “as an ordered combination, this iterative process allows a user to access more electronic pictorial data in a more rapid fashion. The distributed data sources permit a user to access masses of data, while the recursive division step permits a user to access that data quickly, with increasing resolution over time. . . .”

Finally, the Court addressed one of the Alice exceptions, finding that the invention described by the claims is necessarily rooted in computer technology: “The elements of the method described in the [patent] are not merely what a computer does; they are a specific procedure that is done by a computer. . . . Claim 1 recites a specific way of overcoming a problem which plagued prior art systems. This specific solution . . . demonstrates a sufficient inventive concept.”

1. A method of providing a pictorial representation of space-related data of a selectable object, the representation corresponding to a view of the object by an observer with a selectable location and a selectable direction of view comprising:

(a) providing a plurality of spatially distributed data sources for storing space-related data;

(b) determining a field of view including an area of the object to be represented through a selection of a distance of the observer to the object and an angle of view of the observer to the object;

(c) requesting data for the field of view from at least one of the plurality of spatially distributed data sources;

(d) centrally storing the data for the field of view;

(e) representing the data for the field of view in a pictorial representation having one or more sections;

(f) using a computer, dividing each of the one or more sections having image resolutions below a desired image resolution into a plurality of smaller sections, requesting higher resolution space-related data for each of the smaller sections from at least one of the plurality of spatially distributed data sources, centrally storing the higher resolution space-related data, and representing the data for the field of view in the pictorial representation; and

(g) repeating step (f), dividing the sections into smaller sections, until every section has the desired image resolution or no higher image resolution data is available.

Read: 101 Frustrations



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