IP Law Daily, PATENT—D. Del.: Judgment on pleadings of invalidity granted in computer authentication dispute, (Jul 30, 2025)

By Kevin M. Finson, J.D.

Claims relating to secure transmission of data using a distance measurement between devices were unpatentable as abstract because they simply recited the use of generic computer components to carry out the abstract idea of transmitting data when certain conditions were met.

A seller of computer technology was entitled to judgment on the pleadings because the patent claims asserted against it were directed to the unpatentable abstract idea of transmitting data when certain conditions were met, the U.S. District Court in Wilmington has held. The asserted patent did not claim a technological improvement but merely used generic computer components to carry out an abstract idea (Media Content Protection LLC v. Realtek Semiconductor Corp., No. 1:20-cv-01247-CFC-LDH (D. Del. July 28, 2025)).

Media Content Protection, LLC (Media) was the owner of U.S. Patent No. 10,298,564 (the ’564 patent), which was entitled "Secure Authenticated Distance Measurement" and which related to determining whether data stored on one device was to be accessed by a second device. Media brought suit for infringement against Realtek Semiconductor Corp. (Realtek). Realtek moved for judgment on the pleadings, arguing that the ’564 patent was invalid for being directed at an abstract idea. The court applied the two-step Alice test.

Abstract idea. Media argued that the claims of the ’564 patent were directed to “combining an authenticated distance measurement with a certificate-based authentication protocol." The court found that data transfer, even when combined with some sort of condition precedent like measuring distance, was an abstract idea.

The court noted that the patent claims used generic, results-oriented language to describe a device capable of executing instructions to provide a certificate, to generate a signal from a secret, to provide that signal to another device, and to receive protected content from that other device, all without explaining how these things were actually done. Because this did not reflect an improvement in technology, but rather the use of well-known methods and conventional components, the court found that it was directed to an abstract idea.

Inventive concept. The court found that the patent lacked any additional limitations that could form an inventive concept, as it simply directed the use of generic computer components to carry out the abstract idea.

The court granted judgment on the pleadings in favor of Realtek.

The Case is No. 1:20-cv-01247-CFC-LDH.

Judge: Connolly, C.

Attorneys: Brian E. Farnan (Farnan LLP) for Media Content Protection LLC. John G. Day (Ashby & Geddes P.A.) for Realtek Semiconductor Corp.

Companies: Media Content Protection LLC; Realtek Semiconductor Corp.

Cases: Patent DelawareNews