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Section 101 Intellectual Property Protection Abstract Ideas

Quarles & Brady LLP

New Federal Circuit Decision - Expect Getting AI/Machine Learning Patents Past 101 to Get Tougher

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The Federal Circuit recently issued a decision in Recentive Analytics, Inc. v. Fox Corp., invalidating the patent claims at issue as directed to ineligible subject matter under 35 U.S.C. § 101. In what it noted was a case of...more

Miller Canfield

A New Alice Plot Twist - Can a Composition of Matter Be an Abstract Idea?

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The patent world tends to think that the Supreme Court’s framework in Alice is a template for determining the eligibility of software and business method inventions. Under 35 U.S.C. § 101, abstract ideas are not eligible for...more

Holland & Knight LLP

Access Denied: Patent for Controlling Entry Found Ineligible Under Section 101

Holland & Knight LLP on

Earlier this month in Luxer Corp. v. Package Concierge, the U.S. District Court for the District of Delaware found that U.S. Patent No. 11,625,675 was ineligible under Section 101. In assessing the defendant's motion to...more

McDermott Will & Emery

Federal Circuit Polishes § 101’s Abstract Idea Test

McDermott Will & Emery on

The US Court of Appeals for the Federal Circuit reversed and remanded a determination by the US International Trade Commission regarding subject matter ineligibility under 35 U.S.C. § 101. The Court concluded that the...more

Holland & Knight LLP

Section 101 Patent Eligibility Roundup: It's Been Too Long

Holland & Knight LLP on

It's been a while since I last posted, and I apologize for that. (If interested, here's an alert about what's kept me away: a CFAA trial we wrapped up in late July.) But I am back, so let's look at the latest on the Section...more

Baker Botts L.L.P.

The Importance of Prong Two of Step 2A for AI inventions

Baker Botts L.L.P. on

Under the direction of President Biden’s executive order on artificial intelligence (AI), the United States Patent and Trademark Office (USPTO) issued a guidance update on the subject matter eligibility analysis “to promote...more

Mayer Brown

USPTO Provides Insight Into Patent Eligibility in the Context of AI

Mayer Brown on

As required by President Joe Biden’s Executive Order on the Safe, Secure, and Trustworthy Development and Use of Artificial Intelligence, the United States Patent and Trademark Office (“USPTO”) issued the Guidance on Patent...more

Sheppard Mullin Richter & Hampton LLP

Federal Circuit Applies WesternGeco Framework to Expert’s Effort to Seek Royalties Flowing from Customers Overseas

In 2010, Trading Technologies International, Inc. (“TT”) filed suit against IBG LLC and its subsidiary Interactive Brokers LLC for patent infringement. The four patents in question, U.S. Patent Nos. 6,766,304; 6,772,132;...more

Sheppard Mullin Richter & Hampton LLP

2023 Federal Circuit Case Summaries - Intellectual Property: Year End Report

We are pleased to share Sheppard Mullin’s inaugural “Year in Review” report that collects and reports on most key patent law-related Federal Circuit decisions for 2023. This is a follow up to the quarterly report we...more

Troutman Pepper Locke

The Patent Eligibility Restoration Act – ‎Restoring Clarity, Certainty, and Predictability to ‎the U.S. ‎‎Patent System

Troutman Pepper Locke on

On June 22, 2023‎, the U.S. senate released a bill, The Patent Eligibility Restoration Act of 2023 (introduced by Senators Tillis and Coons and ‎hereinafter referred to as “PERA”), which if passed would transform patent...more

Holland & Knight LLP

Claim to High-Yield Enzymatic Production of Stevia Compound Held Invalid as Abstract Idea

Holland & Knight LLP on

Naturally occurring compounds generically referred to as steviols are used as sugar substitutes because they impart sweetness without contributing calories. These compounds exist in different forms, with some being sweeter...more

Akin Gump Strauss Hauer & Feld LLP

Senior Circuit Judge Issues Split Decision on Patent Eligibility of Claims Directed to Restricting Access to Computer Files

Senior Circuit Judge Bryson of the Federal Circuit, sitting by designation in the District of Delaware, recently granted-in-part and denied-in-part a Rule 12(c) motion for judgment based on patent eligibility under 35 U.S.C....more

Sheppard Mullin Richter & Hampton LLP

Trinity Info Media, LLC, fka Trinity Intel Media, LLC, v. Covalent, Inc., No. 2022-1308 (Fed. Cir. July 14, 2023) (“Opinion”)

This case addresses whether patents relating to methods and systems for connecting users based on their answers to polling questions claim patentable subject matter under 35 U.S.C. § 101...more

WilmerHale

Open Questions Regarding the Patent Eligibility Restoration Act of 2023

WilmerHale on

United States Senators Thom Tillis (R-NC) and Chris Coons (D-DE) introduced the Patent Eligibility Restoration Act of 2023 (the “Act”) on June 22, 2023. The Act seeks to modify and clarify “patent eligibility jurisprudence...more

Venable LLP

Senators Tillis and Coons Reintroduce Patent Eligibility Reform Legislation

Venable LLP on

On June 22, 2023, Senators Thom Tillis (R-N.C.) and Chris Coons (D-Del.) announced the reintroduction of legislation to reform the patent eligibility requirements under 35 U.S.C. § 101....more

Irwin IP LLP

Automating Without Innovating: Patents Held Invalid

Irwin IP LLP on

People.ai, Inc. v. Clari Inc., 2022-1364, (Fed. Cir. April. 7, 2023) - In an appeal before the Federal Circuit, plaintiff People.ai argued to no avail that the Northern District of California erred in its finding of...more

Knobbe Martens

The Patent Ineligibility of Digital Imaging Processing Method Claims

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SANDERLING MANAGEMENT LTD. v. SNAP INC. Before Chen, Cunningham, and Stark.  Appeal from the United States District Court for the Central District of California. Summary:  The district court properly found that...more

Akin Gump Strauss Hauer & Feld LLP

District Court Dismissed Infringement Claims Regarding Online Video Streaming Because the Patents Recited Patent-Ineligible...

Judge Cronan in the Southern District of New York (S.D.N.Y.) recently granted a motion to dismiss Plaintiff’s complaint because the patents-in-suit are directed to patent-ineligible subject matter under 35 U.S.C. § 101. The...more

Irwin IP LLP

Maintaining § 101 “Till the Cows Come Home”: ChromaDex, Inc. v. Elysium Health, Inc., 2022-1116, (Fed. Cir. Feb. 13, 2023)

Irwin IP LLP on

In a patent dispute between plaintiffs ChromaDex and Dartmouth College and defendant Elysium Health over spilled milk, the Federal Circuit affirmed the Delaware District Court’s grant of summary judgment in favor of the...more

Haug Partners LLP

Got Markedly Different Milk?: The Federal Circuit Weighs in on 101 and Products of Nature

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In ChromaDex, Inc., v. Elysium Health, Inc., a Federal Circuit panel (“Panel”) contributed to the ongoing discussion on patent-eligible subject matter. The Panel affirmed the district court’s judgment that the asserted claims...more

Haug Partners LLP

Hardware-Based Data Structure Found Patent Eligible Under 35 U.S.C. § 101

Haug Partners LLP on

The Federal Circuit recently addressed the issue of patent-eligible subject matter under 35 U.S.C. § 101 once again in ADASA Inc. v. Avery Dennison Corp., No. 22-1092, 2022 U.S. App. LEXIS 34765 (Fed. Cir. Dec. 16, 2022). ...more

Knobbe Martens

Claim Directed to Specific, Hardware-Based Data Structure That Enables Technological Improvement Is Eligible Under § 101

Knobbe Martens on

ADASA INC. v. AVERY DENNISON CORPORATION - Before Moore, Hughes and Stark.  Appeal from the United States District Court for the District of Oregon. Summary: A claim directed to a specific, hardware-based data...more

Knobbe Martens

Federal Circuit Review - October 2022

Knobbe Martens on

Avoiding § 101 Eligibility Issues in Internet-Centric Method Claims - In Weisner v. Google LLC, Appeal No. 21-2228, the Federal Circuit held that the specific implementation of an abstract idea, such as improving Internet...more

Morrison & Foerster LLP - Federal Circuitry

Last Week In The Federal Circuit (October 17 – October 21): Mapping The Section 101 Landscape

As we’ve noted, the Supreme Court is once again considering whether to take up patent eligibility: it recently CVSGed two more Section 101 cases. While we wait for the government’s views, the Federal Circuit will continue...more

Knobbe Martens

A Computer Method Claim Must Improve the Functions of the Computer to Survive § 101

Knobbe Martens on

Summary: A patentee’s allegation that computer method claims made data analysis more efficient, without reference to the function or operation of the computer itself, was not sufficient to overcome a challenge under 35 U.S.C....more

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