{"id":1289,"date":"2016-10-17T10:04:13","date_gmt":"2016-10-17T14:04:13","guid":{"rendered":"https:\/\/patents.harnessip.com\/?p=1289"},"modified":"2016-10-18T11:06:49","modified_gmt":"2016-10-18T15:06:49","slug":"claims-for-a-new-abstract-idea-are-still-claims-to-an-abstract-idea-invalid-under-%c2%a7101","status":"publish","type":"post","link":"https:\/\/patents.harnessip.com\/?p=1289","title":{"rendered":"Claims for a New Abstract Idea are Still Claims to an Abstract Idea, Invalid under \u00a7101"},"content":{"rendered":"

In Synopsis, Inc. v. Mentor Graphics Corporation<\/em>, [2015-1599] (October 17, 2016), the Federal Circuit affirmed summary judgment that\u00a0claims of U.S. Patent Nos.\u00a05,530,841; 5,680,318; and 5,748,488\u00a0were invalid under\u00a035 U.S.C. \u00a7101. \u00a0The Federal Circuit rejected the argument that the claims were directed to eligible\u00a0subject matter\u00a0because they relate to complex algorithms used in computer-\u00a0based synthesis of logic circuits, instead finding that the are directed to the abstract idea of translating a functional
\ndescription of a logic circuit into a hardware component\u00a0description of the logic circuit.<\/p>\n

The Federal Circuit said that the\u00a0idea of reviewing a\u00a0description of certain functions and turning it into a\u00a0representation of the logic component that performs those\u00a0functions can be\u2014and, indeed, was\u2014performed mentally\u00a0or by pencil and paper by one of ordinary skill in the\u00a0art. \u00a0Furthermore the Federal Circuit said that the claims did not\u00a0call for the involvement\u00a0of a computer, and thus they cannot be characterized as\u00a0an improvement in a computer as a tool.<\/p>\n

At Step I\u00a0of the Alice test, the Federal Circuit said that it continues to\u00a0treat analyzing
\ninformation by steps people go through in their minds, or\u00a0by mathematical algorithms, without more, as essentially\u00a0mental processes within the abstract-idea category. \u00a0The justification for this is that\u00a0computational methods\u00a0which can be performed entirely in the human\u00a0mind are the types of methods that embody the\u00a0\u201cbasic tools of scientific and technological work\u201d\u00a0that are free to all men and reserved exclusively\u00a0to none.<\/p>\n

Synopsis argued that the complexity of the claims indicated that the method could not be performed mentally, but the Federal Circuit said that claims covered methods that could be performed mentally. \u00a0While Synopsys may be correct that the inventions were intended to be used in conjunction\u00a0with computer-based design tools, the claims were not confined to that conception, and the \u00a7101\u00a0inquiry must focus on the language of the claims themselves.<\/p>\n

At Step II of the Alice test, the Federal Circuit rejected the argument that the novelty of the claims saved them from being abstract, noting that\u00a0a claim for a new<\/em> abstract idea is
\nstill an abstract idea, and concluded that the search for a \u00a7 101 inventive\u00a0concept is distinct from demonstrating \u00a7 102 novelty. \u00a0 Although conceding that the contours of what constitutes an\u00a0inventive concept are far from precise, the Federal Circuit said that the claims\u00a0contain no technical\u00a0solution. To the extent the claims add anything\u00a0to the abstract idea (of translating a functional description\u00a0of a logic circuit into a hardware component description\u00a0of the logic circuit), it is the use of assignment
\nconditions as an intermediate step in the translation\u00a0process. \u00a0But, because\u00a0the claims are for a mental\u00a0process, assignment conditions, which merely aid in\u00a0mental translation as opposed to computer efficacy, are\u00a0not an inventive concept that takes the claims
\nbeyond their abstract idea.<\/p>\n

 <\/p>\n","protected":false},"excerpt":{"rendered":"

In Synopsis, Inc. v. Mentor Graphics Corporation, [2015-1599] (October 17, 2016), the Federal Circuit affirmed summary judgment that\u00a0claims of U.S. Patent Nos.\u00a05,530,841; 5,680,318; and 5,748,488\u00a0were invalid under\u00a035 U.S.C. \u00a7101. \u00a0The Federal Circuit rejected the argument that the claims were directed … Continue reading →<\/span><\/a><\/p>\n","protected":false},"author":2,"featured_media":0,"comment_status":"closed","ping_status":"open","sticky":false,"template":"","format":"standard","meta":{"footnotes":""},"categories":[15],"tags":[],"class_list":["post-1289","post","type-post","status-publish","format-standard","hentry","category-15"],"post_mailing_queue_ids":[],"_links":{"self":[{"href":"https:\/\/patents.harnessip.com\/index.php?rest_route=\/wp\/v2\/posts\/1289","targetHints":{"allow":["GET"]}}],"collection":[{"href":"https:\/\/patents.harnessip.com\/index.php?rest_route=\/wp\/v2\/posts"}],"about":[{"href":"https:\/\/patents.harnessip.com\/index.php?rest_route=\/wp\/v2\/types\/post"}],"author":[{"embeddable":true,"href":"https:\/\/patents.harnessip.com\/index.php?rest_route=\/wp\/v2\/users\/2"}],"replies":[{"embeddable":true,"href":"https:\/\/patents.harnessip.com\/index.php?rest_route=%2Fwp%2Fv2%2Fcomments&post=1289"}],"version-history":[{"count":1,"href":"https:\/\/patents.harnessip.com\/index.php?rest_route=\/wp\/v2\/posts\/1289\/revisions"}],"predecessor-version":[{"id":1290,"href":"https:\/\/patents.harnessip.com\/index.php?rest_route=\/wp\/v2\/posts\/1289\/revisions\/1290"}],"wp:attachment":[{"href":"https:\/\/patents.harnessip.com\/index.php?rest_route=%2Fwp%2Fv2%2Fmedia&parent=1289"}],"wp:term":[{"taxonomy":"category","embeddable":true,"href":"https:\/\/patents.harnessip.com\/index.php?rest_route=%2Fwp%2Fv2%2Fcategories&post=1289"},{"taxonomy":"post_tag","embeddable":true,"href":"https:\/\/patents.harnessip.com\/index.php?rest_route=%2Fwp%2Fv2%2Ftags&post=1289"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}