Open Text S.A. v. Box, Inc.
Opinion
Lead Opinion
Donato, J.
ORDER GRANTING RULE 12(C) MOTION FOR JUDGMENT OF INVALIDITY OF GROUPWARE PATENTS
Re: Dkt. No. 295
Defendant Box moves for judgment of invalidity on the pleadings on the grounds that plaintiff Open Text’s “Groupware” patents 1 claim patent-ineligible subject matter. See Dkt. No. 295. The common specification of the five Groupware patents describes the unremarkable concept of people working together on a project:
’177 patent, 1:11-20. As the specification suggests, this concept existed well before the invention of the Groupware patents. The Groupware patents’ alleged innovation is to facilitate workplace collaboration through the Internet or an intranet without specialized software or calling on a system administrator or IT person for help. Id. 1:5-8. The problem with the asserted claims is that their core concept is inherently abstract, and their implementation, which consists of standard technology like browsers, servers, and networks, has nothing inventive whatsoever about it. The result is that the asserted claims of the Groupware patents are invalid under 85 U.S.C. § 101 . Consequently, the motion is granted.