Regents of the University of Minnesota v. AT&T Mobility LLC
- John Tunheim
- 0:14-cv-04666
- U.S. District Court · District of Minnesota
- 13
In Regents v. AT&T Mobility, Judge Tunheim denied AT&T’s late challenge to the patent’s eligibility and denied Regents’ request to strike as moot.
Regents of the University of Minnesota and AT&T Mobility LLC; the court’s ruling left the ’768 patent eligibility challenge unresolved in AT&T’s favor and denied Regents’ request to strike the motion as moot.
What happened
Regents of the University of Minnesota v. AT&T Mobility LLC concerns AT&T’s challenge to the University’s ’768 patent, which covers techniques intended to improve the speed and reliability of wireless communications. AT&T argued that the patent claimed an abstract idea without an inventive concept.
AT&T filed its motion for judgment on the pleadings nearly a year after the deadline for dispositive motions, without showing good cause or obtaining the court’s permission. The court also considered the patent’s eligibility and concluded that the representative claim was directed to specific improvements in wireless transmission, including techniques to address fading, reduce interference, and improve system performance.
Judge John R. Tunheim denied AT&T’s motion for judgment on the pleadings because it was untimely and lacked merit. The court denied Regents’ letter request to strike AT&T’s motion as moot.
The detailed version
- Regents of the University of Minnesota v. AT&T Mobility LLC · No. 0:14-cv-04666
- John Tunheim
- Aug. 22, 2024
Background
The case concerns the ’768 patent, on which Regents bases Count One of its amended complaint. The patent describes methods for improving wireless communication by combining error-control coding and complex-field linear precoding. The specification addresses “fading,” or interference in wireless mobile communications. The parties focused on Claim 13 as representative. That claim describes a system with a transmitter and receiver using an error-control coder, bit interleaver, mapping unit, precoder, symbol interleaver, and modulator.
AT&T previously filed summary-judgment motions, which the court denied, and the court set the case for trial. Nearly one year after the June 1, 2023, dispositive-motion deadline, AT&T filed a motion for judgment on the pleadings. AT&T argued that the ’768 patent was invalid under Section 101 of the Patent Act because it was directed to an abstract idea and lacked an inventive concept. Regents opposed the motion.
Timeliness
The court treated AT&T’s motion under Federal Rule of Civil Procedure 12(c), which uses the same standard as a motion to dismiss for failure to state a claim. The court held that AT&T’s motion was procedurally improper because it was filed after the dispositive-motion deadline. AT&T had not shown good cause and had not obtained the court’s consent to file the late dispositive motion.
The court rejected AT&T’s argument that the motion should be allowed merely because it would not delay trial. The court explained that allowing AT&T to rely on materials previously submitted during claim construction and summary judgment would undermine filing deadlines and word limits. Although other courts had considered late Rule 12(c) motions, the court concluded that those decisions did not require it to consider AT&T’s motion.
Patent Eligibility
The court also addressed the merits. Section 101 generally permits patents for new and useful processes, machines, manufactures, compositions of matter, and improvements, but excludes laws of nature, natural phenomena, and abstract ideas. Under the two-step Mayo framework, the court first asks whether the claims are directed to an ineligible concept. If so, it asks whether the claims contain an “inventive concept” that adds significantly more than the ineligible concept itself.
The court held that Claim 13 satisfied the first step. Although the claim used mathematical processes, the court found that it was directed to specific improvements in wireless technology rather than an abstract idea for which computers or communications equipment served merely as tools. The claim’s specific combinations of coding, interleaving, mapping, precoding, and modulation were directed to solving fading, gaining diversity, reducing interference, and improving wireless mobile communication performance.
Because the court found the patent eligible at step one, it did not proceed to step two. The court also stated that whether the claimed techniques were known in the prior art was not a reason to find the patent ineligible under Section 101 at step one.
Disposition
The court denied AT&T’s Motion for Judgment on the Pleadings [Docket No. 748]. It also denied Regents’ Letter Requesting the Court Strike Defendant’s Motion [Docket No. 755] as moot.
Read the full 13-page opinion on CourtListener, the free public archive maintained by the Free Law Project.