Archive | June, 2015

PTAB Finds Patent Claims Directed to Organizing Digital Images Patent-Ineligible in CBM Review

The Patent Trial and Appeal Board (“PTAB”) has held all claims of U.S. Patent No. 7,260,587 patent-ineligible under 35 U.S.C. § 101, and the rubric of Alice Corp. v. CLS Bank.  Bank of America, NA v. Intellectual Ventures II LLC, Case CBM2014-00033 (PTAB May 18, 2015). The claims of the ’587 patent are directed to […]

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PTAB Invalidates Financial Administration Patent Claims in CBM Review

Patent claims directed to “administration of financial accounts” are not patent-eligible under 35 U.S.C. § 101, held the Patent Trial and Appeal Board (“PTAB”) during a Covered Business Method (“CBM”) post-grant review. The final written decision from the PTAB found all claims of U.S. Patent No. 8,083,137 unpatentable under 35 U.S.C. § 101. Intellectual Ventures […]

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Functionally-Described Structural Recitations in Method Patent Claims Can Be Indefinite

A patent claim’s recitation of a structural feature was held indefinite under 35 U.S.C. § 112 because the court found that that the claim term in question – “processing system” – was indefinite functional language. Thus, the court in Cox Communications v. Sprint Communications, No. 12-487-SLR (D. Del. May 15, 2015) granted partial summary judgment […]

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Patent Claims Directed to Filtering Internet Content Not Patent-Eligible

Patent claims directed to “filtering Internet content” were held invalid under 35 U.S.C. § 101 in Bascom Global Internet Servs., Inc. v. AT&T Mobility LLC, No. 3:14-cv-3942-M (N.D. Tex May 15, 2015). The court held that, under Alice Corp. Pty. Ltd. v. CLS Bank Int’l., 134 S. Ct. 2347 (2014), the claims were directed to […]

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Means-Plus-Function Claims Are Dangerous in Software Patents

The latest example of the danger of drafting software patent claims to include means-plus-function limitations comes from Eon Corp. IP Holdings LLC v. AT&T Mobility LLC, No. 2014-1392 (Fed. Cir. May 6, 2015).  U.S. Patent No. 5,663,757 included eight “means” limitations that the district court had held indefinite under 35 U.S.C. 112.  These limitations required […]

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