Patent claims directed to a remote user interface displaying a plurality graphical user interfaces (GUIs) were held not patent eligible under 35 U.S.C. § 101 in Valmont Industries, Inc. v. Lindsay Corporation, No. 15-42-LPS (D. Del. Nov. 14, 2018). The Court found that the claims of U.S. Pat. No. 7,003,357 were directed to the abstract idea of “remotely monitoring and controlling irrigation equipment” without an inventive concept, granting a motion to dismiss under F.R.C.P. 12(b)(6).
Claim 25, added in the first ex parte reexamination and the focus of this decision, recites:
A remote user interface for reading a status of and controlling irrigation equipment including a pivot and at least two end-guns affixed to the pivot, comprising:
a hand-held display;
wireless telemetry means for transmitting signals and data between the remote user interface and the irrigation equipment; and
software operable on said processor for:
(a) displaying data received from the irrigation equipment as a plurality of graphic user interfaces (GUIs) that are configured to present said data as status information on said display, wherein said plurality of GUIs are shaped to identify particular types of irrigation equipment by comprising a pivot GUI that represents the pivot, at least two end-gun GUIs that represents the at least two end guns affixed to the pivot, and a spray pattern GUI that represents a setting of the at least two end-guns along a pivot path; wherein the pivot GUI has a shape representing the pivot path of the pivot, the shape partitioned into a plurality of wedges; wherein the spray pattern GUI has a spray pattern representing the setting of the at least two end-guns along the pivot path;
(b) receiving a user's commands to control the irrigation equipment, through said user's manipulation of said GUIs, wherein receiving the user's commands comprises: receiving the user's selection of a wedge; and receiving the user's selection of a change of a status of one of the least two end-guns for the selected wedged; and
(c) transmitting signals to the irrigation equipment to control the irrigation equipment in accordance with said user's commands; and
(d) displaying a changed spray pattern of the selected wedge according to the change of the status of one of the least two end-guns.
Plaintiff argued that the claims are directed to patent-eligible concept of “graphical user interfaces that are shaped to represent one or more data whose shape may change in response to changes in the data.” However, the Court noted that “the claims do not capture Plaintiff’s purported innovation: the use of compact and efficient GUIs on a small screen” and denied further discovery.
For the first step of the Alice test, Plaintiff argued that the claims provide “specific improvements to irrigation control systems comprising innovative GUIs for monitoring and controlling irrigation equipment via a hand-held device.” Relying on Core Wireless v. LG Elecs., Plaintiff argued that GUIs are not per seabstract. 880 F.3d 1356 (Fed. Cir. 2018). The Court agreed that the GUIs of Core Wireless were not abstract, but only because those asserted claims specified the innovation and improvements of those displays. In contrast, claim 25 merely applied irrigation data to a GUI, and thus was directed to the abstract idea of “remotely monitoring and controlling irrigation equipment.”
For the second step of the Alice test, the Court notes that “the specification describes the invention, but never articulates patentable solutions to prior art problems.” The alleged improvement in portability was performed by standard communications systems, processors, and displays. Because Plaintiff could not demonstrate the specific technical implementation and improvement, the Court dismissed Plaintiff’s assertions that claim 25 included an inventive concept and held claim 25 ineligible under § 101.
Lessons for Practice
Graphical interfaces are tough to patent. The Court here discusses at length the recent cases regarding the Alice test. Indeed, the Court seems to take to heart the rapidly changing understanding of patent-eligible subject matter and the evidentiary burdens required. And the Court spells out Plaintiff’s fatal problem: “the claims do not capture Plaintiff’s purported innovation.” This case further emphasizes that courts look for clear technical solutions to technical problems supported by evidence for patent eligibility.