Although a jury found in February that New Life is liable for $75,000 in damages for infringing the patents owned by inventor Emmanuel C. Gonzalez, Judge Gilstrap on Tuesday granted New Life summary judgment that the patents are invalid.
The patents describe "a method for multiparameter digital labeling of Internet websites" and a database of such labels. Judge Gilstrap, who was assigned 1,615 patent cases last year, far more than any other judge, said the patents cannot stand under Alice, which held that abstract ideas implemented using a computer are not patent-eligible.
He held that the patents describe only "routine tasks that could be performed by a human" and that applying the idea of labeling to websites to is not inventive enough to be patent-eligible.
"The claims themselves offer nothing more than taking the well-known concept of labeling and applying it to the Internet," he wrote. "The court finds that this application does support finding an inventive concept to be present in the asserted patents."
In the brief order, which contains only about two pages of analysis of patent-eligibility, Judge Gilstrap wrote that Gonzalez's patents were were similar to one for an online "shopping cart" asserted by a company called eDekka LLC that he invalidated in September.
That case attracted considerable attention because knocked out 168 suits that eDekka had filed against retailers like Forever 21 Inc. and because Judge Gilstrap had granted few motions invalidating patents under Alice up to that point.
He later ordered eDekka to pay $390,829 in attorneys' fees to the accused infringers for filing suit over a patent that he called "demonstrably weak on its face." Attorneys have suggested that those rulings have contributed to 47 percent drop in new suits in the Eastern District of Texas in the first quarter of 2016, as nonpracticing entities that have favored the Eastern District of Texas worry that they could face similar outcomes.
Gonzalez sued New Life Ventures, a Miami-based data processing company over the patents in 2014, alleging that its website infringes.
Attorneys for the parties could not immediately be reached for comment Thursday.
The patents-in-suit are U.S. Patent Numbers 7,873,665 and 7,558,807.
Gonzalez is represented by M. Scott Fuller, Jason Mueller, Paul Lein and Darrian Campbell of Locke Lord LLP.
New Life Ventures is represented by Nicholas Brown and Stephen Ullmer of Greenberg Traurig LLP.
The case is Gonzalez v. New Life Ventures Inc., case number 2:14-cv-00907, in the U.S. District Court for the Eastern District of Texas.
--Editing by Katherine Rautenberg.