Here are brief summaries of nine recent cases in which district courts have considered validity of patent claims under 35 U.S.C. 101. The trend is not good for patent owners. Two Patents Survive a Rule 12 Alice Challenge . . . Mirror Worlds Technologies LLC v. Apple Inc., No. 6:13-CV-419 (E.D. Texas July 7, 2015). Judge Schroeder in the Eastern District of Texas denied without prejudice a motion for judgment on the pleadings (albeit after claim construction). Claims of U.S. Patent No. 6,006,227 were directed to more than the abstract idea of organizing documents. In particular, the court stated that the claims required “the computer to maintain data units in a persistent mainstream of all data units received or generated and at least one persistent substream.” Even if pre-computer analogs were well-known and conventional, these recitations of computer activity were not. Execware LLC v. BJ’s Wholesale Club Inc., No. 1-14-cv-00233…
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