Last week, Delaware District Judge Colm F. Connolly issued orders considering two magistrate recommendations: a first, agreeing that a case filed against Apple and Visa by inventor-controlled Universal Secure Registry LLC (USR) should not be transferred to the Northern District of California; and a second, disagreeing that a motion challenging the four patents at issue in that same case under Alice should be denied. In the latter, Judge Connolly ruled that the asserted claims are patent-ineligibly directed to the abstract idea of “the secure verification of a person’s identity”, ending the litigation. Though less consequential in light of that Alice ruling, litigants before Judge Connolly may still want to take note that the transfer denial order does reinforce an expansive reading of one of the relevant factors.
