The U.S. District Court for the Northern District of California has dismissed a lawsuit against Amazon.com filed by TriDim Innovations claiming patent infringement.
TriDim filed a suit on Nov 30th 2015 for infringing two patents (U.S. Patent No. 5,838,326 and 5,847,709) on a “computer controlled display system” which it acquired from Xerox Corp. It claims that Amazon.com uses similar software for its Kindle Fire.
The patents describe a three-dimensional computer document workspace that allows users to consolidate a large number of documents by touching, dropping and flicking them into three separate places in accordance to their usage.
Amazon.com argued that the patents were invalid under section 101 as applied in the Alice Corp. Pty. Ltd v. CLS Bank Int’l in 2014. In the Alice case, the Supreme Court expressed that computer claims are eligible for patents if there is significantly more than an abstract idea.
TriDim reasoned that separating its computer display into three spaces limits their invention to a specific system, and hence it is not an abstract idea.
The judge of the case, James Donato found the patent to be invalid under Alice as it was an abstract idea of retrieval and arranging of documents. He ruled it out by saying it did not establish an inventive concept and is a “common solution to a common problem.”
The court said that the TriDim patents did not require any specific hardware or software that would help a user to move and place files within the system. Furthermore, it found that there was an overuse of the word “circuitry” but the invention had nothing to with circuitry. It also said that inclusion of smart words does not mean that the creation is an innovative concept.
Due to all of these assertions, the court gave verdict in favor of Amazon.com and dismissed the lawsuit. The ruling came out on Sept 19, 2016, just days before the patents were about to expire.
According to the USPTO data and MaxVal’s own research, here is a detailed history of this infringement case
|Court||California Northern District Court|
|Plaintiff||Tridim Innovations LLC|
|Plaintiff Attorney||Steven Todd Lowe|
|Plaintiff Law Firm||Lowe & Associates, P.C.|
|Defendant Attorney||Daniel Thomas Shvodian|
|Defendant Law Firm||Perkins Coie LLP|
|Product||Various versions of the Kindle Fire, Kindle Fire HD, Kindle Fire HDX, and Fire phone – products that incorporate the “carousel” feature|
|Basis of Termination||Judgment on the Merits|
|Outcome of District court judgment||Favor of Defendant|
|Comments||Patent claims ruled invalid|