IP Blog
DDR Holdings
Uniloc Communications System Patent Survives § 101 Challenge Based on Technical Improvement: Uniloc USA, Inc. v. LG Electronics USA, Inc.
Patent claims directed to a communication system recite a technical solution and therefore, the Federal Circuit held, are not patent-ineligible under 35 U.S.C. § 101 and the two-part Mayo/Alice test. Uniloc USA, Inc. v. LG Electronics USA, Inc., No. 2019-1835 (Fed. Cir. April 30, 2020) (precedential) (opinion by Judge Moore, joined by Judges Reyna and Taranto). The court thus reversed Judge Koh...
Your Garage Door Opener Is Not Patent-Eligible
Patent claims directed to a “movable barrier operator,” i.e., controlling a garage door, are not patent-eligible under 35 U.S.C. § 101 and the Alice/Mayo test. Chamberlain Group, Inc. v. Techtronic Industries Co. Ltd., Nos. 2018-2103, 2018-2228 (Fed. Cir. Aug. 21, 2019) (precedential) (Judge Chen, joined by Judges O’Malley and Lourie). There are a lot of lessons in this procedurally rich post-trial...
Check Processing Claims Fail Alice Test at Federal Circuit
Patent claims directed to a “method for processing paper checks” are invalid under 35 U.S.C. § 101 and the Mayo/Alice abstract idea test, the Federal Circuit held in Solutran, Inc. v. Elavon, Inc., Nos. 2019, 1345, 2019-1460 (July 30, 2019) (opinion by Judge Chen; joined by Judges Hughes and Stoll) (precedential). The court reversed a denial a motion for summary...
Phone Registration Verification Patents Easily Fail Alice
Claims of four patents directed to using a telephone to verify a person registering for an account are invalid under 35 U.S.C. § 101 and the Alice patent-eligibility test, the court held in TeleSign Corporation v. Twilio, Inc., Case No. 18-cv-03279-VC (N.D. Cal. Oct. 19, 2018). Accordingly, the court granted a Rule 12(c) motion for judgment on the pleadings that asserted claims...
DDR and Enfish Can’t Save Software Fault Recovery Claims
Claims directed to “software fault recovery” are patent-ineligible under 35 U.S.C § 101, said the court in Atticus Research Corp. v. MMSoft Design Ltd., No. 4:17-CV-3387 (S.D. Texas Sept. 6, 2018), granting a Rule 12(b)(6) motion to dismiss allegations that claims of U.S. Patent No. 6,567,937 were infringed. The court agreed with the defendant that the claims were directed to the...
DDR Holdings Saves Other DDR Holdings Patents
The Federal Circuit’s famous (or infamous) decision that one DDR Holdings’ patent was not invalid under 35 U.S.C. § 101 was used to support a district court’s denial of a motion for judgment of § 101 for three other DDR Holdings’ patents. In DDR Holdings, LLC v. Priceline.com, LLC, No. 17-498 (D. Del. June 5, 2018), the court denied a...