CAFC Affirms Rule 12(b)(6) 101 Dismissal for Google in Precedential Ruling on Software Claims
Briefly

CAFC Affirms Rule 12(b)(6) 101 Dismissal for Google in Precedential Ruling on Software Claims
"The U.S. Court of Appeals for the Federal Circuit (CAFC) on Thursday, January 22, issued a precedential decision affirming a district court ruling that granted Google's motion to dismiss a patent owner's infringement suit for failure to state a claim. The CAFC agreed with the district court that the software claims in question were directed to a patent-ineligible abstract idea. The opinion was authored by CAFC Chief Judge Moore and joined by Judges Hughes and Stoll."
"U.S. Patent No. 7,679,637 LLC sued Google in the U.S. District Court for the Western District of Washington for infringing certain claims of its patent, titled "Time-shifted Web Conferencing." Google moved to dismiss under Federal Rule of Civil Procedure 12(b)(6), arguing the asserted claims are patent- ineligible under 35 U.S.C. § 101. The district court granted Google's motion, finding that the claims were directed to the abstract idea of "playing back recorded content.""
The CAFC affirmed a district court ruling that granted Google's motion to dismiss for failure to state a claim. The court found the asserted software claims were directed to a patent‑ineligible abstract idea. U.S. Patent No. 7,679,637 LLC sued Google over claims in U.S. Patent No. 7,679,637, titled 'Time‑shifted Web Conferencing.' The district court determined the claims were directed to playing back recorded content. On appeal, the patent owner asserted a specific improvement enabling asynchronous review. The CAFC concluded the claims failed to describe how asynchronous review is achieved and cited controlling precedent.
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