{"id":1936,"date":"2018-01-25T12:58:30","date_gmt":"2018-01-25T17:58:30","guid":{"rendered":"https:\/\/patents.harnessip.com\/?p=1936"},"modified":"2018-02-03T14:33:33","modified_gmt":"2018-02-03T19:33:33","slug":"computer-interface-was-not-an-abstract-idea","status":"publish","type":"post","link":"https:\/\/patents.harnessip.com\/?p=1936","title":{"rendered":"Computer Interface Was Not an Abstract Idea"},"content":{"rendered":"

In Core Wireless Licensing S.A.R.L. v. LG Electronics, Inc.<\/a>, [2016-2684, 2017-1922](January 25, 2018), the Federal Circuit affirmed the denial of summary judgment that claims 8 and 9 of\u00a0U.S. Patent No. 8,713,476 and claims 11\u00a0and 13 of U.S. Patent No. 8,434,020 are\u00a0directed to patent ineligible subject matter under 35\u00a0U.S.C. \u00a7 101; (2) the denial of JMOL that\u00a0Blanchard anticipates the\u00a0asserted claims under 35 U.S.C. \u00a7 102; and (3) the denial of JMOL that the claims are not\u00a0infringed.<\/p>\n

The\u00a0 patents disclose improved display\u00a0interfaces, particularly for electronic devices with small\u00a0screens like mobile telephones, which allow a user to more quickly\u00a0access desired data stored in, and functions of applications\u00a0included in, the electronic devices.\u00a0 Claim 1 was representative of the claims of the ‘476 patent:<\/p>\n

1. A computing device comprising a display\u00a0screen, the computing device being configured to\u00a0display on the screen a menu listing one or more\u00a0applications, and additionally being configured to\u00a0display on the screen an application summary
\nthat can be reached directly from the menu,\u00a0wherein the application summary displays a limited\u00a0list of data offered within the one or more applications,\u00a0each of the data in the list being\u00a0selectable to launch the respective application and\u00a0enable the selected data to be seen within the respective\u00a0application, and wherein the application\u00a0summary is displayed while the one or more applications\u00a0are in an un-launched state.<\/p>\n

LG moved for summary judgment of invalidity of the\u00a0asserted claims under 35 U.S.C. \u00a7 101, which the court\u00a0denied, finding that\u00a0crediting LG\u2019s characterization\u00a0of the claims as directed to \u201cdisplaying an application\u00a0summary window while the application is in an unlaunched\u00a0state,\u201d the concepts of \u201capplication,\u201d \u201csummary\u00a0window,\u201d and \u201cunlaunched state\u201d are specific to devices\u00a0like computers and cell phones, and explaining that LG identified no analog to these concepts\u00a0outside the context of such devices, and further alternatively finding claim 1 patent eligible at least because it passes the\u00a0machine-or-transformation test.<\/p>\n

The Federal Circuit conducted the Alice<\/em> two-step analysis, noting that at step one it must \u201carticulate what the claims are\u00a0directed to with enough specificity to ensure the step one\u00a0inquiry is meaningful.\u00a0 The Federal Circuit pointed out the difficulty inherent in delineating the contours of\u00a0an abstract idea, and observing that all inventions at some level embody,\u00a0use, reflect, rest upon, or apply laws of nature,\u00a0natural phenomena, or abstract ideas.\u201d The Federal Circuit also considered\u00a0whether the claims are directed to a\u00a0specific improvement in the capabilities of computing\u00a0devices, or, instead, a process that qualifies as an abstract\u00a0idea for which computers are invoked merely as a
\ntool.<\/p>\n

The Federal Circuit asserted claims in this case are directed to an improved\u00a0user interface for computing devices, not to the\u00a0abstract idea of an index, as argued by LG.\u00a0Although the generic idea of summarizing information\u00a0certainly existed prior to the invention, these claims are\u00a0directed to a particular manner of summarizing and
\npresenting information in electronic devices.\u00a0 \u00a0The Federal Circuit disclosed invention improves the efficiency of using\u00a0the electronic device by bringing together a limited
\nlist of common functions and commonly accessed stored\u00a0data ,\u201d which can be accessed directly from the main\u00a0menu. The Federal Circuit found that the\u00a0this language clearly indicates that the claims\u00a0are directed to an improvement in the functioning of
\ncomputers, particularly those with small screens.\u00a0 Referring to the language of the specification, the Federal Circuit found that it the claims were\u00a0directed to an improvement in the functioning of\u00a0computers, particularly those with small screens.<\/p>\n

Having determined that the claims were not directed to an abstract idea, the Federal Circuit did not reach the second part of the Alice<\/em> test.<\/p>\n

On the anticipation issue, the Federal Circuit found that LG failed to carry its burden to show the claims anticipated.\u00a0 On the infringement issue, the Federal Circuit found that because the claim language, specification, and prosecution
\nhistory all support the district court\u2019s construction, that this construction was correct. Further, the Federal Circuit found substantial evidence supports the jury\u2019s verdict\u00a0of infringement based. While\u00a0LG argued no reasonable
\njury could find the accused devices satisfy this claims the Federal Circuit disagreed.<\/p>\n","protected":false},"excerpt":{"rendered":"

In Core Wireless Licensing S.A.R.L. v. LG Electronics, Inc., [2016-2684, 2017-1922](January 25, 2018), the Federal Circuit affirmed the denial of summary judgment that claims 8 and 9 of\u00a0U.S. Patent No. 8,713,476 and claims 11\u00a0and 13 of U.S. Patent No. 8,434,020 … 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-1936","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\/1936","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=1936"}],"version-history":[{"count":3,"href":"https:\/\/patents.harnessip.com\/index.php?rest_route=\/wp\/v2\/posts\/1936\/revisions"}],"predecessor-version":[{"id":1939,"href":"https:\/\/patents.harnessip.com\/index.php?rest_route=\/wp\/v2\/posts\/1936\/revisions\/1939"}],"wp:attachment":[{"href":"https:\/\/patents.harnessip.com\/index.php?rest_route=%2Fwp%2Fv2%2Fmedia&parent=1936"}],"wp:term":[{"taxonomy":"category","embeddable":true,"href":"https:\/\/patents.harnessip.com\/index.php?rest_route=%2Fwp%2Fv2%2Fcategories&post=1936"},{"taxonomy":"post_tag","embeddable":true,"href":"https:\/\/patents.harnessip.com\/index.php?rest_route=%2Fwp%2Fv2%2Ftags&post=1936"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}