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Fed. Cir. Affirms It: Facilitating Cross-Marketing Relationships an Invalid Abstract Idea

On Tuesday, the Federal Circuit affirmed a District of Delaware decision without a written opinion. The Delaware decision, from late 2018, granted LinkedIn's motion to dismiss the plaintiff's patent suit, finding the asserted...more

Fed. Cir. Examines Expert Declarations and Unasserted Claims in Recent § 101 Decision

Earlier this month, the Federal Circuit ruled on an interesting case that discussed (1) when a case or controversy exists as to unasserted patent claims, and (2) the extent expert declarations affect a patent eligibility...more

D. Utah Cellspin Not Section 101 Intervening Law

This summer, the District of Utah dismissed Simio’s lawsuit against Flexsim Software, finding that the asserted patent was not patent eligible under Section 101. Simio responded by asking the court to vacate its judgment or,...more

USPTO Updates Its 2019 Patent Eligibility Guidelines

Late last week, the United States Patent and Trademark Office (USPTO) published updated guidance to patent examiners for evaluating subject matter eligibility. This update was in response to comments received in response to...more

Bloomberg Law: There is a Lack of Consensus among Stakeholders on Patent Eligibility Reform

As we know, Senators Thom Tillis (R-N.C.) and Chris Coons (D-Del.) introduced a draft bill months ago that would "reform Section 101 of the Patent Act" and followed that up with a series of congressional hearings. Senator...more

Peer-to-Peer Employment Verification Patent Directed to Unpatentable Subject Matter

Tenstreet asserted its patent against DriverReach, a recruiting company for hiring CDL drivers, in the Southern District of Indiana. DriverReach moved to dismiss the complaint, arguing that the asserted patent was directed to...more

S.D.N.Y.: Money Transfer Patent Directed to Patent-Ineligible Subject Matter

Western Express Bancshares (WEB) alleged that Green Dot’s sale of debit cards infringed WEB’s patent, which was directed to a method of transferring money through a bank card where (1) the card was linked to a bank account,...more

Tax Preparation Patent Directed to an Abstract Idea

PTP OneClick asserted its ’915 patent against Avalara in the Western District of Washington; the court quickly dismissed those claims and held that the asserted claims were directed to “the abstract concept of calculating and...more

Rep. Collins (R-Ga.) Calls for Patent Reform After American Axle Decision

We wrote about the Federal Circuit’s American Axle decision last week, highlighting Judge Kimberly Moore’s fierce dissent. Judge Moore was not the only person with a strong reaction. A day after the decision, Rep. Doug...more

A Federal Circuit Quarrel: Patent Eligibility, Enablement and a Fiery Dissent

There is an ongoing struggle over § 101: the Federal Circuit struggles over the appropriate scope; the lower courts struggle to apply the Federal Circuit's decisions; litigants struggle due to the aforementioned. This has...more

Dog Tug Toy Withstands Section 101 Challenge (N.D. Illinois)

FYF-JB sued Pet Factory for allegedly infringing a patent related to a tug toy that comprises: at least one gripping member; a central portion; and a noise maker designed to emit a sound when one applies force. The patent...more

We Have a Jury Verdict on Patent Eligibility

The Berkheimer effect is real and may be a lifeline for a plaintiff to survive a motion to dismiss or summary judgment. But at some point, those genuine disputes of material fact will be put to a jury....more

Federal Circuit: Commercial Success is Not Relevant to Alice Analysis

The Patent Trial and Appeal Board (PTAB) rejected all pending claims of Mr. Greenstein’s patent application, which was directed to adjusting the amount a person saves and choosing investments with the goal of saving enough...more

Let It Ride: Gambling Patent Survives Early Section 101 Challenge, Requires Claim Construction

The plaintiff asserted four sports gambling patents against two defendants. The Patent Trial and Appeal Board (PTAB) instituted inter partes review proceedings on three of the asserted patents and defendants moved to dismiss...more

Patent Directed to Testing Electronic Circuits Using a Laser Beats § 101 Challenge

Plaintiff SEMICAPS filed suit in the Northern District of California, alleging infringement of U.S. Patent No. 7,623,982, which relates to the testing of electronic circuits using a laser. The defendants moved to dismiss the...more

Federal Circuit: Construe Disputed Claim Terms Before Deciding § 101 Eligibility

The Federal Circuit – in a split decision – remanded a recent N.D. California decision and held that the district court should have construed a disputed claim term before ruling on patent eligibility. MyMail asserted...more

E.D. North Carolina Axes Patent Directed to Teaching Guitar

Rocksmith sued Yousician Oy, alleging infringement of its patent entitled "interactive guitar game." The patent discloses software for learning to play the guitar and provides an "effective way to provide interactive method...more

Federal Circuit Ruling Kills Labrador Retriever Genotyping Patent

The Federal Circuit provided an undesirable reminder to The University of Bern (and many other patent owners): a positive and valuable contribution does not necessarily equate to patentable subject matter. Here, the Court...more

Call Interface Patent Survives Early Section 101 Challenge in Delaware

Mod Stack accused Aculab of infringing U.S. Patent No. 7,460,520, which relates to "a system and method for simultaneously interfacing with different types of call controllers in a voice gateway." The patent specification...more

Federal Circuit: Reordering Conventional Steps Insufficient to Constitute an Inventive Concept

Last week, the Federal Circuit reversed a District of Minnesota decision and found a patent directed to a system and method for processing paper checks to be abstract and not eligible for patent protection. Judge Chen wrote...more

Trade Secret Claims Related to Hacking of DNC’s Computers Dismissed With Prejudice

In a well-publicized litigation, the Democratic National Committee (DNC) sued the Russian Federation for "unlawfully hacking into the DNC's computers in connection with the 2016 presidential election and thereafter...more

It's Not You; It's Your Patent: Dating App Patent Held To Be Abstract, Ineligible

NetSoc filed suit against several online dating platforms, alleging infringement of its patent entitled "Method and System for Establishing and Using a Social Network to Facilitate People in Life Issues." The defendants moved...more

D. Delaware Invalidates Patent Directed to Onsite Data Backup; Discusses Role of Evidence, USPTO and Preemption

The District of Delaware recently found a patent directed to onsite data backup to be abstract and ineligible for patent protection. The court's discussion went beyond the standard Alice inquiry, and touched on the roles of...more

Pennsylvania’s “Gist of the Action” Doctrine Does Not Preclude Trade Secret Claims

Pittsburgh Logistics (PL) sued its competitor and former employee, alleging that the employee breached his employment agreement by working for the competitor and that he would inevitably disclose PL's confidential and trade...more

Aesthetic Appeal of a Patent's Claimed Design Is Inadequate to Render It Functional

• In a relatively rare opinion regarding design patents, the U.S. Court of Appeals for the Federal Circuit weighed in recently on the requirements for design patents in its Automotive Body Parts Association v. Ford Global...more

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