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Solicitor General Files Brief in Berkheimer v. HP

Berkheimer v. HP Inc. was decided by the Federal Circuit in February 2018 and stands for -- in the words of Judge Moore of that Court -- "the unremarkable proposition that whether a claim element or combination of elements...more

Koninklijke KPN N.V. v. Gemalto M2M GmbH (Fed. Cir. 2019)

Koninklijke KPN N.V. (KPN) sued Gemalto M2M GmbH (Gemalto) and several other parties in the District of Delaware for infringement of its U.S. Patent No. 6,212,662.  The defendants moved for dismissal under Rule 12(c),...more

USPTO Subject Matter Eligibility October Update: Example 46

Last month the U.S. Patent and Trademark Office published an update ("October Update") to its subject matter eligibility guidance.  As we noted at that time, the October Update is more evolutionary than revolutionary, and...more

USPTO Publishes Update to Its Subject Matter Eligibility Guidance

Early today, October 17, 2019, the U.S. Patent and Trademark Office released an update to its January 2019 Subject Matter Eligibility Guidance.  Unlike the January Guidance, which represented a significant change in how the...more

Federal Circuit Invalidates A. G. Bell's Telegraphy Patent

June 23, 1880 - WASHINGTON D.C.  In a unanimous panel ruling, the Federal Circuit invalidated a patent owned by Salem, Massachusetts inventor A. G. Bell.  On February 14, 1876, Mr. Bell was granted Letters Patent No....more

The Chamberlain Group, Inc. v. Techtronic Industries Co. (Fed. Cir. 2019)

Another week and another technology patent falls to a patentable subject matter challenge under Alice Corp. v. CLS Bank Int'l.  In this case, the patentee may have effectively shot itself in the foot with its own statements...more

MyMail, Ltd. v. ooVoo, LLC (Fed. Cir. 2019)

MyMail is the holder of U.S. Patent Nos. 8,275,863 and 9,021,070, both directed to "methods of modifying toolbars that are displayed on Internet-connected devices such as personal computers."  MyMail initially asserted these...more

ChargePoint, Inc. v. SemaConnect, Inc. (Fed. Cir. 2019)

On July 23, 2019, the Federal Circuit denied ChargePoint's request for panel rehearing and en banc review of its March 28, 2019 decision rendering four ChargePoint patents invalid under 35 U.S.C. § 101.  Since we did not...more

The PTAB Goes to Europe: Four Recent Section 101 Decisions Designated as Informative

On July 1, the Patent Trial and Appeal Board (PTAB) of the U.S. Patent and Trademark Office (USPTO) designated four of its recent 35 U.S.C. § 101 decisions as informative.  Each of these decisions came down after and applied...more

Cellspin Soft, Inc. v. Fitbit, Inc. (Fed. Cir. 2019)

Cellspin Soft Inc. (Cellspin) filed an infringement suit against Fitbit Inc. (Fitbit) and ten other defendants in the Northern District of California, asserting U.S. Patent Nos. 8,738,794, 8,892,752, 9,258,698, and...more

Senators Tillis and Coons Release Statement on Recent Patent Reform Hearings

As we have previously covered, the Senate Subcommittee on Intellectual Property recently held hearings on proposed revisions to 35 U.S.C. § 101 and related sections of the patent statute. Chairman Thom Tillis (a Republican...more

Senate Subcommittee on Intellectual Property Holds Hearings on Proposed Revisions to 35 U.S.C. § 101

On June 4, 5, and 11, the Senate Subcommittee on Intellectual Property held hearings on its recent proposal to revise 35 U.S.C. § 101, and in particular the current draft bill to do so.  Chairman Tillis and Ranking Member...more

Congress Proposes Draft Bill to Change 35 U.S.C. § 101

On May 22, a bipartisan and bicameral group of senators and representatives released a draft bill that proposes significant changes to 35 U.S.C. § 101 and the law of patent eligibility.  This draft bill follows a framework...more

USPTO on Patent Eligibility -- Examples 41 and 42

On January 7, 2019, the U.S. Patent and Trademark Office published updated examination guidance, instructing the examining corps and the PTAB how they should apply 35 U.S.C. § 101. On the same day, the USPTO also published...more

USPTO on Patent Eligibility -- Example 40

On January 7, 2019, the U.S. Patent and Trademark Office published updated examination guidance, instructing the examining corps and the PTAB how they should apply 35 U.S.C. § 101. On the same day, the USPTO also published...more

USPTO on Patent Eligibility -- Examples 38 & 39

On January 7, 2019, the U.S. Patent and Trademark Office published updated examination guidance, instructing the examining corps and the PTAB how they should apply 35 U.S.C. § 101. On the same day, the USPTO also published...more

USPTO on Patent Eligibility -- Example 37

On January 7, 2019, the U.S. Patent and Trademark Office published updated examination guidance, instructing the examining corps and the PTAB how they should apply 35 U.S.C. § 101. On the same day, the USPTO also published...more

USPTO Issues Updated Subject Matter Eligibility Guidance

On January 4, the U.S. Patent and Trademark Office published updated examination guidance regarding the subject matter eligibility of inventions involving abstract ideas. The guidance went into effect on January 7, upon its...more

In re Marco Guldenaar Holding B.V. (Fed. Cir. 2018)

One final 35 U.S.C. § 101 case inched across the finish line at the end of 2018. And while this one is not particular remarkable substantively, its concurrence from a particularly opinionated judge may give it an unwelcome...more

Overcoming 35 U.S.C. § 101 Rejections Based on Electric Power Group

Opening scene . . . our intrepid patent attorney arrives early at her office for a productive day at work. With morning coffee sitting next to her monitor, she opens her email. She finds a few messages from clients and...more

Ancora Technologies, Inc. v. HTC America, Inc. (Fed. Cir. 2018)

Ancora sued HTC in the Western District of Washington alleging infringement of U.S. Patent No. 6,411,941. HTC moved to dismiss the case, contending that the claims of the patent were ineligible under 35 U.S.C. § 101. The...more

Data Engine Technologies LLC v. Google LLC (Fed. Cir 2018)

Data Engine Technologies (DET) filed an infringement suit against Google in the District of Delaware contending infringement of U.S. Patent Nos. 5,590,259, 5,784,545, 6,282,551, and 5,303,146. Google responded with a Rule...more

The Subject Matter Eligibility of Machine Learning: An Early Take

Machine learning is more than just a buzzword. It represents a fundamental shift in how problems are solved across industries and lines of business. In the near future, a machine learning library may become a standard part...more

Interval Licensing LLC v. AOL, Inc. (Fed. Cir. 2018)

Interval Licensing brought an action against AOL and several other defendants in the Western District of Washington, alleging infringement of U.S. Patent No. 6,034,652. In a previous ruling, all asserted claims of this...more

Federal Circuit Denies En Banc Review of Berkheimer and Aatrix

One of the more substantive questions in the recent interpretation of what encompasses patentable subject matter under 35 U.S.C. § 101 is whether facts should play any role in the analysis. The Supreme Court has not been...more

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