The Court of Appeals for the Federal Circuit affirmed a decision Friday from the Northern District of California, holding three patents owned by Dropbox, Inc. are ineligible under 35 U.S.C. § 101. The appeals court found that the patents claim abstract ideas and that the claims provide no inventive concept transforming the abstract idea into patentable subject matter.
Dropbox originally sued Synchronoss Technologies, Inc. for patent infringement in June of 2018. The three asserted patents, U.S. Patent Nos. 6,178,505, 6,058,399, and 7,567,541, relate to, respectively, “Secure Delivery of Information in a Network,” “File Upload Synchronization,” and a “System and Method for Personal Data Backup for Mobile Customer Premises Equipment.” A Dropbox subsidiary asserted infringement of the ‘541 patent in a separate lawsuit. Synchronoss filed a motion to dismiss each suit, “arguing that the patents are invalid due to their ineligibility under 35 U.S.C. § 101.” District Court Judge Lucy H. Koh agreed and dismissed the suits and Dropbox appealed.
Regarding the ‘505 patent, the circuit judges’ held “we agree with the district court that the claims of the ’505 patent are ineligible. Both claim 1 and claim 8 are directed to abstract ideas.” The district court held claim 1 of the ‘505 patent was directed to “(1) associating a security level with a data resource, (2) associating a security level with a mode of identification of a user, and then (3) ensuring that the user’s security level is sufficiently high to meet the security level of the data resource to access the data resource.” The district court added that “Such a focus constituted an abstract idea because “the claim does not provide any limits that curb how the apparatus performs these functions” and “invokes computers merely as tools to execute fundamental data access control principles,” “fall[ing] squarely within the [abstract] category of controlling access to data.”
The circuit judges also agreed with the district court’s analysis in regards to the ‘399 and ‘541 patents, finding both were directed to abstract ideas. For the ‘399 patent the court stated it “claims its improvements in an abstract manner,” and “[t]o claim a technological solution to a technological problem, the patent must actually claim the technological solution.” Specifically, “[n]either a single session ID associating between the two connections nor a synchronizer synchronizing the operation amount to a non-abstract improvement—that is, a technological solution.” In their reasoning for the ‘541 patent the court noted Dropbox argued the patent’s data structure is inventive, but the court disagreed because the “inventive concept must be evident in the claims.” The court stated “no data structures—much less any inventive data structures—are evident in the claims.”
The appellants were represented by Wilmer Cutler Pickering Hale and Dorr LLP, while the appellees were represented by Dentons US LLP. The panel of judges consisted of Chief Judge Prost, and Circuit Judges Wallach and Hughes.
