Precedential Federal Circuit Opinions
1. NATURE SIMULATION SYSTEMS INC. v. AUTODESK, INC. [OPINION] (2020-2257, 10/17/2022) (Newman, Lourie, and Dyk)
Newman, J. The Court reversed a district court judgment that the asserted patent claims were invalid as indefinite. The Court held that "the district court erred on the legal standard for claim indefiniteness, and that on the correct standard the claims are not indefinite." The Court explained that the claimed subject matter was an improvement on certain known methods and "partakes of known usages for these established technologies." The Court concluded that the general approaches referenced in the patent were "sufficiently well established in the art" that the claims were not indefinite.
2. IBM v. ZILLOW GROUP, INC. [OPINION] (2021-2350, 10/17/2022) (Reyna, Hughes, and Stoll)
Hughes, J. The Court affirmed a district court's judgment on the pleadings that two patents were invalid because they claimed abstract ideas that are ineligible for patenting under 35 U.S.C. § 101. With respect to the first patent, the Court explained that the claims are directed to the abstract steps of "presenting a map, having a user select a portion of that map, and then synchronizing the map and its corresponding list to display a more limited data set to the user." In addition, the Court found that the claims do not add any inventive concept to the abstract idea because the claim "limitations use functional language, at a high level of generality and divorced from any computer technology, to recite the claimed functions." With respect to the second patent, the Court held that the claims are "directed to the abstract idea of organizing and displaying visual information." The Court also concluded that the claims do not add any inventive concept to the abstract idea because the claims "merely used well-understood, routine, or conventional technology (a general-purpose computer) to more quickly solve the problem of layering and displaying visual data."
3. FINJAN LLC v. ESET, LLC [OPINION] (2021-2093, 11/01/2022) (Prost, Reyna, and Taranto)
Reyna, J. The Court reversed-in-part, vacated-in-part, and remanded the district court's summary judgment of invalidity for certain patents "directed to systems and methods for detecting computer viruses in a 'Downloadable' through a security profile." The district court had found the patents invalid as indefinite based on its construction of the claim term "Downloadable." The Court reversed the district court's claim construction and vacated its indefiniteness determination, concluding that the term "Downloadable" as used in the asserted patents means: "an executable or interpretable application program, which is downloaded from a source computer and run on the destination computer."
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