Crandall Technologies LLC v. VUDU, Inc.

Background

Crandall Technologies LLC asserted claims from the ’341 and ’720 patents against VUDU, Inc. The opinion describes the claims as involving transmitting instructions or other data from one device to another. Crandall characterized the claims as covering remotely launching an application on one device from another, using touchscreen gestures, and choosing the second device based on a display parameter. The complaint focused on a system for selecting a video on one device and playing it on a second device.

VUDU moved to dismiss under the rule allowing dismissal at the pleading stage. The court considered whether the identified patent claims were eligible for protection under 35 U.S.C. § 101.

Court’s analysis

The court applied the two-part patent-eligibility framework. First, it held that claims 4, 6, 10, 13, and 15 of the ’341 patent, and claims 1, 2, 8, and 17 of the ’720 patent, were directed to the abstract idea of transmitting information—including instructions and other data—from one device to another. The court said that the claims did not improve the functionality of a computer or network. Instead, they used existing solutions, including wireless networks, touchscreens, and data analysis.

Second, the court held that the claims lacked an inventive concept—an additional feature or combination that transforms an abstract idea into a patent-eligible application. The claims described generic devices connected through a generic wireless data-sharing network, with software allowing a user to select content on one device and display it on another. The court said that using technology was not the same as improving the technology itself. It also rejected Crandall’s argument that claim 4 of the ’341 patent contained an inventive concept because it used a display parameter to determine the second device’s display capabilities.

The court further held that deciding invalidity under Section 101 did not depend on genuinely disputed facts. It found that Crandall’s citations to the patent specifications did not identify a factual dispute that could change the abstract-idea or inventive-concept analysis. The court therefore concluded that resolving the issue at the motion-to-dismiss stage was appropriate.

Disposition

The court granted VUDU’s motion to dismiss. It held the specified claims of the ’341 and ’720 patents invalid under 35 U.S.C. § 101 and dismissed Crandall’s claims with prejudice.