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Useful Improvement to Computer Network Using Standard Equipment Held Patent Eligible | Manatt, Phelps & Phillips, LLP

Useful Improvement to Computer Network Using Standard Equipment Held Patent Eligible | Manatt, Phelps & Phillips, LLP

In Cooperative Entertainment, Inc. v. Kollective Technology, Inc.,1 the Federal Circuit held that useful improvements to computer networks can be patent eligible even when standard computing equipment is used. In addition, assertions by a patent owner in a complaint that the inventive concept included a specific network structure for sharing content through a dynamic peer-to-peer (P2P) network were sufficient to prevent dismissal of the case for lack of patent eligibility.

Cooperative Entertainment, Inc. (Cooperative) owned U.S. Patent No. 9,432,452 (’452 patent), directed to configuring a peer-to-peer (P2P) dynamic network for transmitting large files, such as videos and video games, where the distribution of content is performed outside of content distribution networks (CDNs), i.e., outside of a static network of controlled systems. Dynamic P2P networks with peer nodes that process the same content concurrently were used to send the content to each other as an alternative to receiving the

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