Abstract Idea. The claim at issue is directed to a system that allows participants in an instant messaging session to exchange both audio and text messages, and then logs a unified transcript of those messages. The court found that the claim recites an abstract idea of "combining different message types in a single transcript." Although Ginegar identified a purported improvement to instant messaging technology, i.e., "automatically creating a single chat transcript with both text and audio messages," the court noted that it was insufficient. Ginegar failed to show how the claimed invention solved a problem in instant message systems and merely relied on an improved result — "the unified chat transcript."
No Inventive Concept. The court also found that the claim lacks an inventive concept. The purported inventive concept — "the logic element that logs a single transcript of audio and text messages exchanged during an instant messaging session" — is nothing more than using a computer to perform the abstract idea itself. The court emphasized that whether the claim recites an inventive concept "goes beyond what was simply known in the prior art." Ginegar failed to explain how "logging the unified chat transcript" is "anything more than the abstract idea itself, let alone adds something 'significantly more.'"
This case shows that the
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