Adaptive Streaming Inc. v. Netflix, Inc. (Fed. Cir. 2020)

By Michael Borella — Adaptive Streaming, the owner of U.S. Patent No. 7,047,305, sued Netflix in the Central District of California for alleged infringement. Netflix moved to dismiss the case on the pleadings under Rule 12(b)(6), asserting that the claims did not meet the subject matter eligibility requirements of 35 U.S.C. § 101. The District Court agreed, and Adaptive appealed. Representative claim 39 of the ‘305 patent recites: A system to broadcast to at least one client device, the system comprising: a processor; and a broadcasting server coupled to the processor, the broadcasting server including: an image retrieval portion to…