Realtime Data LLC v. Array Networks Inc.

21-2251, 21-2291

Issue(s) Presented

1. “Did the district court err in concluding that all seven asserted patents in three distinct patent families comprising 211 total claims, each of which discloses discrete methods and systems for digital data compression aimed at solving known problems in conventional data compression systems, are directed to an abstract idea?”

2. “Did the district court err in concluding, without considering the claim elements as an ordered combination, that all 211 patent claims lack inventive concept, simply because some of the individual claim limitations utilize generic computer components?”

3. “Did the district court err in disregarding the patents’ claimed advances and resolving disputed issues of fact to hold that the patents claim ineligible subject matter, despite the statements in the patent specifications and Realtime’s detailed factual allegations in the amended complaints demonstrating that the disclosed methods of digital data compression were not well-understood, routine, or conventional?”


1.  “In sum, the claims of the asserted patents are ‘data manipulation’ claims that are recited at a high ‘level of result-oriented generality’ and that lack ‘sufficient recitation of how the purported invention[s] accomplish the results’ and “thus ‘amount[] to a mere implementation of . . . abstract idea[s].’”

2. “In short, we see nothing in the individual limitations or their ordered combination that transform the claims into patent-eligible subject matter” and therefore the claims do “‘not contain an inventive concept.’”

3.  “Realtime further contends that the ’751 patent provides ‘unconventional technological solutions in digital data transmission,’ by, for instance, providing ‘transmission and transparent multiplication of digital data communication bandwidth, as well as a potential reduction of the latency associated with data transmission of conventional systems.’ . . . Data transmission, however, is an abstract idea that does not provide an inventive concept. . . . And Realtime’s assertion of a potential reduction of the latency ‘amounts to no more than a restatement of the assertion that the desired results are an advance.’ . . . We have considered Realtime’s other arguments and find them unpersuasive.”