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American Axle: After Solicitor General Weighs In, Neapco Responds and Court Sets Conference

I first wrote on American Axle back in 2019. Nearly three years and dozens of hits for "American Axle" on hklaw.com later, we'll finally get an answer to whether the U.S. Supreme Court will hear another Section 101 dispute....more

Patent Claiming Mapping Gemstones to Blockchain Invalid Under Section 101

In a recent case decided by the U.S. District Court for the Southern District of New York, the plaintiff, Max Rady, alleged that he developed a method to "record to a blockchain the individual identification signatures of...more

Federal Circuit: Failure to Preserve Key Argument Blunts Section 101 Eligibility Appeal

In Travel Sentry, Inc. v. Tropp, 2022 WL 443202 (Fed. Cir. Feb. 14, 2022), Mr. Tropp alleged infringement of two of his related patents. The parties agreed at the U.S. District Court for the Eastern District of New York that...more

U.S. Patent Office Introduces Deferred Subject Matter Eligibility Response Pilot Program

The U.S. Patent and Trademark Office (USPTO) has introduced its Deferred Subject Matter Eligibility Response Pilot Program, which will evaluate the effects of permitting applicants to defer responding to subject matter...more

Top Section 101 Patent Eligibility Stories of 2021

It's that time of the year again. Take your rapid test, light a fire and gather with family and friends to discuss the top patent eligibility stories of 2021 (or debate "The Holiday" vs. "Love Actually"). No. 3: More of...more

D. Ariz.: Exchanging Geographic and Demographic Data is not Patent Eligible under Section 101

In the case USADATA Inc. v. DataWidget LLC, No. CV-21-00526-PHX-DLR, 2021 WL 5084283 (D. Ariz. Nov. 1, 2021), the patent at issue is titled, "System and Method for Selling Customer-Specific Data Subsets on a Third-Party...more

Section 101 Patent Eligibility at the Supreme Court: Where Are We?

Dennis Crouch at Patently-O has a breakdown of the patent cases currently pending before the U.S. Supreme Court. As he notes, a number of these cases could be transformative if certiorari is granted, including American Axle...more

Southern District of New York: Digital Mapping Patent Fails Under Section 101

Disclosure: Holland & Knight LLP, including the authors of this blog post, represents Polar Electro in the litigation described below. In the case of Jewel Pathway LLC v. Polar Electro Inc., No. 20 CIV. 4108 (ER), 2021 WL...more

Fed. Circ.: Retailer Finder Fee Patent Invalid Under Section 101

In the case of In re Elbaum, No. 2021-1719, 2021 WL 3923280 (Fed. Cir. Sept. 2, 2021), Saul Elbaum applied for a patent related to selling products on the internet using physical locations, specifically where the internet...more

No Mixed Signals: Delaware Court Finds Data Transmission Patent Invalid Under Section 101

In Zyrcuits IP LLC v. Acuity Brands, Inc., No. CV 20-1306-CFC, 2021 WL 3287801, at *1 (D. Del. Aug. 2, 2021), Zyrcuits IP sued a number of defendants in the U.S. District Court for the District of Delaware, alleging...more

It Is Time to Air your Section 101 Patent Eligibility Grievances

Grab your aluminum pole because it's time for the airing of [patent eligibility] grievances. The U.S. Patent and Trademark Office (USPTO), at the request of Sens. Thom Tillis (R-Texas), Mazie Hirono (D-Hawaii), Tom...more

A Bad Day for this Patent Applicant: Travel Itinerary Applications Ineligible Under Section 101

In the case of In re Bongiorno, No. 2020-1835, 2021 WL 1997454, at *4 (Fed. Cir. May 19, 2021), patent applicant James Bongiorno appealed the Patent Trial and Appeal Board's (PTAB) finding that two of his patent applications...more

Federal Circuit: Method of Creating a Floral Arrangement is an Abstract Idea

In the case of In re Sturgeon, 839 F. App'x 517, 520 (Fed. Cir. 2021), the patent application claimed a method of creating a floral arrangement on an electronic display screen with the following representative claim: A...more

Federal Circuit Invalidates Patent Directed to Customer Loyalty and Rewards System

In cxLoyalty Inc. v. Maritz Holdings Inc., 986 F.3d 1367, 1380 (Fed. Cir. 2021), Patent No. 7,134,087 explained that loyalty programs often issue points to customers as a reward for certain activities and allow the customers...more

Federal Circuit Confirms Data Privacy Patent Is an Invalid Abstract Idea under Section 101

The U.S. Court of Appeals for the Federal Circuit looked at a patent directed to a data privacy system that described users operating mobile device apps to "socialize, bank, shop, and navigate." As users operate such apps,...more

Patent Directed to Countering Credit Card Fraud is an Invalid Abstract Idea Under Section 101

In the case of In Re: SARADA MOHAPATRA, Appellant, No. 2020-1935, 2021 WL 408755 (Fed. Cir. Feb. 5, 2021), Sarada Mohapatra sought to overturn a decision of the Patent Trial and Appeal Board (PTAB), holding that his patent...more

USPTO Director Iancu Calls for Section 101 Patent Eligibility Reform in Farewell Speech

U.S. Patent and Trademark Office (USPTO) Director Andrei Iancu recently resigned his position with the USPTO and delivered his farewell speech at a U.S. Chamber of Commerce event on Jan. 19, 2021. In the speech, Iancu...more

Will 2021 Be the Year the U.S. Supreme Court Again Addresses Section 101 Eligibility?

In 2020, the U.S. Supreme Court declined to hear Section 101 patent eligibility cases again, and again, and again. But is 2021 the year that the Supreme Court finally addresses the topic? Maybe. I'm hesitant to say yes....more

Court: Improved User Experience Doesn't Improve Computer Functionality Under Alice

In 2019, the U.S. District Court for the District of Utah dismissed Simio's lawsuit against FlexSim Software, finding that the asserted patent was ineligible under Section 101. Simio responded by asking the court to vacate...more

Top Section 101 Patent Eligibility Stories of 2020

Light a fire, pour yourself some glogg (21+) and find a comfy corner to read about the biggest Section 101 stories of 2020 because we're gonna have the hap-hap-happiest time since Bing Crosby tap-danced with . . . Well, you...more

Patents Directed to a Media Player that Provides Information with Media Content Fail under Section 101

Disclosure: Holland & Knight LLP, including the author of this blog post, represents Polar Electro in the litigation described below. Interactive Wearables (IW) sued Polar Electro Oy and Polar Electro Inc., asserting two...more

U.S. Supreme Court Declines to Hear Another Section 101 Case

Those waiting for the U.S. Supreme Court to weigh in on Section 101 were, once again, disappointed this week. On Nov. 16, 2020, in the case of WhitServe LLC v. Donuts Inc. et al., case no. 20-325 (U.S. Supreme Court), the...more

Remote Appliance Control Patent Compared to Pony Express, Invalid Under Section 101

Karamelion has asserted its two patents more than 40 times since the summer of 2018, typically settling the cases prior to a responsive pleading. This activity will have to go on hold, at least for the time being, as the U.S....more

Federal Circuit Remands District Court's "Cursory" Section 101 Analysis for Further Review

Realtime Data filed suit in the U.S. District Court for the District of Delaware against a number of defendants alleging infringement of various combinations of claims from five different patents. The asserted patents had...more

Advantage over Prior Methods Inadequate to Confer Patent Eligibility without Technological Improvement

In a short, two-page opinion, the U.S. Court of Appeals for the Federal Circuit affirmed the U.S. District Court for the Southern District of Indiana's ruling that a method of using peer-to-peer networking to verify...more

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