- with readers working within the Oil & Gas and Law Firm industries
- within Strategy topic(s)
The U.S. Court of Appeals for the Federal Circuit affirmed a district court judgment holding asserted claims of U.S. Patent No. 8,139,652 ineligible under 35 U.S.C. § 101 in Technology in Ariscale, LLC v. Razer USA Ltd., concluding the claims are directed to an abstract idea and lack an inventive concept.
The panel (Sharon Prost, Jimmie Reyna, Tiffany Cunningham) adopted a straightforward Alice/Mayo analysis: The claims recite receiving, manipulating and decoding data using generic computer functionality, and neither their framing nor the asserted order of steps transforms them into a patent-eligible application. The court, as is typical, refused to import performance "improvements" from the specification where the claims do not capture the asserted technical details.
The asserted claims recite "computer-implemented method for decoding a transmission signal" that includes four steps: receiving the transmission signal, deinterleaving, combining symbols at the same positions of deinterleaved encoding blocks and decoding the combined symbols.
Alice Step One
The court upheld the district court's characterization of Claim 1 as directed to receiving, manipulating and decoding data. Although the patent owner argued the claims specifically target downlink frame prefix (DFP) information in wireless signals, the claim language did not limit the combining/decoding to DFP content and, instead, contemplated a signal "formed by repeating symbols including [DFP] information." That breadth, coupled with functional recitations implemented on a generic processor, placed the claims within abstraction territory.
The panel also noted the absence of "specific means or method[s]" for performing the claimed invention. In short, the Federal Circuit found that the claim reads as data receipt, reformatting and decoding – fundamental information processing untethered to a particularized technical implementation.
Ariscale's "technological improvement" argument – improved reception performance (bit error rate, signal-to-noise ratio (SNR)) by separately treating DFP – failed because those benefits were not claimed. The court emphasized that reliance on the specification must yield to claim language, and unclaimed details cannot carry the day at step one.
Alice Step Two
At step two, Ariscale argued that the ordered sequence of combining after deinterleaving but before decoding provided an inventive concept. The court rejected that theory for a claim/specification mismatch: The specification teaches that symbol combination and averaging may be performed before deinterleaving and decoding as well, and Claim 2 flips the order while remaining substantively identical. Because the touted performance advantages are not tied to any particular order, the alleged inventive concept cannot rest on ordering.
Nor did any individual step rescue the claims. The specification admits receiving, deinterleaving and decoding were used in prior art methods, leaving "combining" as the only arguably new piece, but the claim says what to combine, not how, and the spec describes the combining as basic arithmetic (adding and averaging), which can be done mentally or by hand. The court reiterated that details living only in the specification cannot supply the inventive concept if they are not in the claims themselves.
Presumption of Validity
Ariscale also argued the district court slighted the presumption of validity, but the Federal Circuit rejected this. The district court expressly recognized the clear-and-convincing standard, and the appellate court reiterated that courts owe no deference to the U.S. Patent and Trademark Office on eligibility.
Curt Cignetti as Claudio Ranieri
A quick non-101 note that came up in a guys' group chat: Is 2025-26 Curt Cignetti 2015-16 Claudio Ranieri? At the college football level, Curt Cignetti has Indiana playing for a national championship on Monday, an outcome that would've been a typo not long ago. The turnaround has been fast and feels oddly inevitable once you actually watch Indiana play.
Across the pond, Claudio Ranieri guiding Leicester City to a Premier League title remains the silver* standard "Wait, this is really happening?" for sports moments. Different sports, different continents, but the theme is the same: a clear plan, buy-in from the players and staff, and a group who never got the memo about limits.
*This remains my gold standard.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
