Precedential Federal Circuit Opinions
- UNIVERSITY OF FLORIDA RESEARCH v. GENERAL
ELECTRIC COMPANY [OPINION - PRECEDENTIAL] (2018-1284,
2/26/19) (Prost, Moore, Wallach)
Moore, J. Affirming grant of motion to dismiss because claims are directed to ineligible subject matter. "On its face, the [asserted] patent seeks to automate 'pen and paper methodologies' to conserve human resources and minimize errors. This is a quintessential 'do it on a computer' patent: it acknowledges that data from bedside machines was previously collected, analyzed, manipulated, and displayed manually, and it simply proposes doing so with a computer... That the automation can 'result in life altering consequences," [citation to patent omitted], is laudable, but it does not render it any less abstract. The [asserted] patent nowhere identifies, and we cannot see in the claims, any 'specific improvement to the way computers operate.'" Also finding that the patent owner waived sovereign immunity as to defendant's § 101 eligibility challenge. - PERSONAL WEB TECHNOLOGIES, LLC v. APPLE, INC.
[OPINION - PRECEDENTIAL] (2018-1599, 3/8/19) (Moore, Taranto,
Chen)
Chen, J. Reversing decision of invalidity in IPR because the Board's finding of inherency was not supported by substantial evidence. "Because we find that the proposed, theoretical Binary Object Identifier look-up table that [petitioner] and the Board rely on does not necessarily exist in [the prior art reference], the Board's reliance on inherency for that element in its obviousness analysis was improper."
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