User-based customization does not by itself amount to significantly more than an abstract idea. Here, for example, a network-based media system having “a customized user interface page for [a] given user” was found to be nothing more than an abstract idea because neither the specification nor the claims were limited to any particular form of customization. “That disclosure and the accompanying ‘customized user interface’ limitation in the claim do not constitute a concrete application of the abstract idea.” It may therefore be best to claim more specifically how something is customized rather than merely the result of customization.
Background / Facts: The patent being asserted here is directed to a network-based media system with a “customized user interface,” in which the system delivers streaming content from a network-based resource upon demand to a handheld wireless electronic device having a graphical user interface.
Issue(s): Whether the customized user interface supplies the inventive concept to the claimed invention.
Holding(s): No. “The term ‘customized user interface,’ as used in the [] patent, is not limited to any particular form of customization, but covers the general idea of customizing a user interface. Like the basic concept of tailoring content to a user, as in Intellectual Ventures I, the basic concept of customizing a user interface is an abstract idea.” Moreover, “neither the claim nor the specification reveals any concrete way of employing a customized user interface. The specification simply states that a user interface can be customized ‘in a plurality of ways’ by allowing users to select and receive ‘on-demand customized audio information.’ [] That disclosure and the accompanying ‘customized user interface’ limitation in the claim do not constitute a concrete application of the abstract idea of delivering content to a wireless device and thus do not embody an ‘inventive concept,’ as that term has been used in the Mayo/Alice line of cases.”