Eolas Technologies Incorporated v. amazon.com, Inc.

CourtCourt of Appeals for the Federal Circuit
DecidedFebruary 1, 2024
Docket22-1932
StatusUnpublished

This text of Eolas Technologies Incorporated v. amazon.com, Inc. (Eolas Technologies Incorporated v. amazon.com, Inc.) is published on Counsel Stack Legal Research, covering Court of Appeals for the Federal Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Eolas Technologies Incorporated v. amazon.com, Inc., (Fed. Cir. 2024).

Opinion

Case: 22-1932 Document: 59 Page: 1 Filed: 02/01/2024

NOTE: This disposition is nonprecedential.

United States Court of Appeals for the Federal Circuit ______________________

EOLAS TECHNOLOGIES INCORPORATED, Plaintiff-Appellant

v.

AMAZON.COM, INC., GOOGLE LLC, WALMART, INC., Defendants-Appellees

---------------------------------------------

GOOGLE LLC, Plaintiff-Appellee

EOLAS TECHNOLOGIES INCORPORATED, Defendant-Appellant

REGENTS OF THE UNIVERSITY OF CALIFORNIA, Defendant ______________________

2022-1932, 2022-1933, 2022-1934, 2022-1935 ______________________

Appeals from the United States District Court for the Northern District of California in Nos. 4:15-cv-05446-JST, 4:17-cv-01138-JST, 4:17-cv-03022-JST, 4:17-cv-03023-JST, Judge Jon S. Tigar. Case: 22-1932 Document: 59 Page: 2 Filed: 02/01/2024

______________________

Decided: February 1, 2024 ______________________

JOHN BRUCE CAMPBELL, McKool Smith, P.C., Austin, TX, argued for plaintiff-appellant. Also represented by JOSHUA WRIGHT BUDWIN, JAMES ELROY QUIGLEY, JOEL LANCE THOLLANDER.

CHARLES KRAMER VERHOEVEN, Quinn Emanuel Ur- quhart & Sullivan, LLP, San Francisco, CA, for defendant- appellee Google LLC. Also represented by JOCELYNE MA, DAVID ANDREW PERLSON; DEEPA ACHARYA, Washington, DC.

GABRIEL K. BELL, Latham & Watkins LLP, Washing- ton, DC, argued for all defendants-appellees. Defendant- appellee Amazon.com, Inc. also represented by RICHARD GREGORY FRENKEL, DOUGLAS ETHAN LUMISH, Menlo Park, CA; JOSEPH HYUK LEE, Costa Mesa, CA; AMIT MAKKER, San Francisco, CA; JEFFREY H. DEAN, Amazon.com, Inc., Seat- tle, WA.

MARK CHRISTOPHER FLEMING, Wilmer Cutler Pickering Hale and Dorr LLP, Boston, MA, for defendant-appellee Walmart, Inc. ______________________

Before CHEN, BRYSON, and STOLL, Circuit Judges. STOLL, Circuit Judge. Eolas Technologies Inc. appeals from the United States District Court for the Northern District of California’s sum- mary judgment holding the asserted claims of Eolas’s U.S. Patent No. 9,195,507 invalid for claiming ineligible subject matter. Because we agree with the district court’s conclu- sion, we affirm. Case: 22-1932 Document: 59 Page: 3 Filed: 02/01/2024

EOLAS TECHNOLOGIES INCORPORATED v. AMAZON.COM, INC. 3

BACKGROUND I The ’507 patent claims priority from a patent filed in 1994. The ’507 patent specification notes that the limited processing power of a typical client computer and the low bandwidth of the Internet prohibited most users from in- teracting with large data objects on the Internet. See ’507 patent col. 5 ll. 39–52, col. 6 ll. 22–33. The specification de- scribes the present invention as taking advantage of dis- tributed hypermedia environments, such as that provided by the World Wide Web, and harnessing the remote com- puting power made available by distributed computing. 1 Id. col. 6 ll. 57–67; see also id. col. 7 ll. 1–6. The specification explains that tasks that would nor- mally be resource or bandwidth-intensive for a single com- puter—such as rendering large images or calculating spreadsheet cells—can be performed more effectively with distributed computing. For example, a new viewpoint of a large image or an updated calculation for a large spread- sheet can be computed on a remote computer and then sent to the client computer for display. See id. col. 7 ll. 1–33. Figure 5, shown below, illustrates an embodiment of the invention.

1 “Distributed” describes objects or processes that are located and/or processed across multiple computers on a network. See, e.g., ’507 patent col. 5 ll. 29–34; see Eolas Techs. Inc. v. Amazon.com, Inc., No. 6:15-cv-01038, 2016 WL 7155294, at *8 (E.D. Tex. Dec. 8, 2016) (Claim Construction Op.) (construing “distributed application” to mean an “application that is broken up and performed among two or more computers”). Case: 22-1932 Document: 59 Page: 4 Filed: 02/01/2024

Id. Fig. 5. In this embodiment, a browser client 208 on the user’s computer requests and parses through a data object (e.g., hypermedia document 212), 2 and identifies an appli- cation for the application client 210 to invoke in order to interact with the data object. See id. col. 9 ll. 4–20, col. 9 ll. 29–33. The application client 210 communicates with the distributed network 206 (e.g., World Wide Web) to ac- cess the data object located on a server computer 204. Id. col. 9 ll. 34–40. Upon receipt of the data object from the application client 210, the browser client 208 displays the data object on the client computer 200. Id. col. 9 ll. 54–57; see also id. col. 9 l. 65–col. 10 l. 3. The specification also describes an example of an application performing multidi- mensional image visualization. Id. col. 9 ll. 34–35. In this

2 A “hypermedia document” is a document presented to a user in a computer system in which “the user is able to click on images, sound icons, video icons, etc., that link to other objects of various media types, such as additional graphics, sound, video, text, or hypermedia or hypertext documents.” ’507 patent col. 2 ll. 22–30. Case: 22-1932 Document: 59 Page: 5 Filed: 02/01/2024

EOLAS TECHNOLOGIES INCORPORATED v. AMAZON.COM, INC. 5

example, application server 220 performs the rendering and transformation calculations as the user interacts with the three-dimensional data object, with application client 210 updating the user’s view with each new viewpoint cal- culation. Id. col. 10 ll. 34–39, ll. 46–54. The specification describes a preferred embodiment in which the user inter- acts with the three-dimensional data object “within, or ad- jacent to, a window generated by browser client 208 that contains a display of hypermedia document 212.” Id. col. 9 ll. 59–61. According to the ’507 patent, having the application server 220 use the computing resources of the server com- puter 204, as described in the three-dimensional visualiza- tion example, is much faster than having the application client 210 executing on the client computer 200. Id. col. 10 ll. 60–64. Eolas argued before the district court that there is no substantial difference between method claims 32, 37, and 39 and system claims 19, 24, and 26. The district court agreed and determined these method claims were repre- sentative of the system claims. See Eolas Techs. Inc. v. Am- azon.com Inc., No. 17-cv-03022, 2022 U.S. Dist. LEXIS 243302, at *53–54 (N.D. Cal. May 16, 2022) (Summary Judgment Op.). Representative independent claim 32 re- cites: 32. A method, performed by a server computer con- nected to the World Wide Web distributed hyper- media network on the Internet, for disseminating interactive content via the World Wide Web dis- tributed hypermedia network on the Internet, the method comprising: A. receiving, by the server computer, a re- quest for information; and B. transferring, by the server computer, the information onto the World Wide Web Case: 22-1932 Document: 59 Page: 6 Filed: 02/01/2024

distributed hypermedia network on the In- ternet, wherein: (i) a World Wide Web browser on a client computer connected to the World Wide Web distributed hyper- media network has been configured with a plurality of different interac- tive-content applications, each said interactive-content application be- ing configured to enable a user to interact, within one or more World Wide Web pages, with at least part of one or more objects while at least part of each of said one or more ob- jects is displayed to the user within at least one of said one or more World Wide Web pages, and (ii) at least part of the information is configured to allow the World Wide Web browser on the client computer to: a. detect at least part of an object to be displayed in a World Wide Web page, and b. cause a display of the World Wide Web page to a user, (iii) the World Wide Web browser has been configured to: a.

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