The United States Court of Appeals for the Federal Circuit found that a representative claim was for an improvement in patent-eligible computing functionality, and therefore overturned a decision drafted by Judge Leonard P. Stark as sitting judge. in the U.S. District District Court. of Delaware. Mentone Solutions LLC v. Digi International Inc., Case n ° 21-1202, -1203 (Fed. Cir. 15 Nov. 2021) (Moore, CJ) (not preceded).
Mentone Solutions sued Digi International for infringement of Mentone’s patent to improve dynamic resource allocation in a GPRS cellular network using staggered uplink status indicators (USF). Digi decided to lay off under Fed. R.Civ. P. 12 (b) (6), arguing that the patent claims were not eligible for patent under 35 USC § 101. The district court allowed the motion to dismiss, finding that the claim of the Representative was not eligible for the patent for being “directed to the abstract idea of receiving a USF and transmitting data during the appropriate time intervals.” Mentone appealed.
The Federal Circuit began its analysis with a detailed explanation of the claimed technology and how its use of an “offset USF” improved the normal operation of the communications system, noting that the offset USF specifically allowed a station mobile to access multiple previously restricted locations. configuration.
Examination of the eligibility determination in § 101 of the district court de novo, the Federal Circuit applied the two-step procedure of the Supreme Court Alice framework, by first determining whether the representative claim was directed at an abstract idea. The Court explained that in cases involving software, the first step is often to determine whether the request is focused on specific stated improvements in computer capabilities rather than on an abstract idea that simply invokes a computer as a tool.
The Federal Circuit compared the request in question to those in question in Packet Intelligence vs. NetScout Sys., in which the Court concluded that the contested claims related to a problem unique to computer networks and that the specification of the patent provided details of how the solution to the network problem had been found. In Packet intelligence, the Court examined the specification of the patent to inform its understanding of the claimed invention and found that the specification clearly indicated that the claimed invention solved a problem unique to computers.
Likewise, in this case, the Federal Circuit explained that the representative’s claim does not cite generalized steps to be performed on a computer, but rather a particular method to break the delay between the downlink USF and the transmission of subsequent uplink. The Court noted that the term “staggered USF” was coined by the inventor, and that the specification and figures informed the Court of the understanding of the term, the claimed invention, the technical solution and how the elements of the claim work together to provide the solution. The Court concluded that the claimed invention solves a unique challenge to computer networks and aims to improve computer and patentable functionality.
The Federal Circuit rejected the district court’s qualification of the claim as directed toward the abstract idea of ”receiving a USF and transmitting data during the appropriate time intervals.” The Court found that the District Court’s wording was an over-simplified high-level description of the general operation of the USF, which did not take into account the operation and use of the claimed displaced USF and other features. related.