Uniloc Communications System Patent Survives § 101 Challenge Based on Technical Improvement: Uniloc USA, Inc. v. LG Electronics USA, Inc.
Patent claims directed to a communication system recite a technical solution and therefore, the Federal Circuit held, are not patent-ineligible under 35 U.S.C. § 101 and the two-part Mayo/Alice test. Uniloc USA, Inc. v. LG Electronics USA, Inc., No. 2019-1835 (Fed. Cir. April 30, 2020) (precedential) (opinion by Judge Moore, joined by Judges Reyna and Taranto). The court thus reversed Judge Koh in the Northern District of California, who had found that claims of U.S. Patent 6,993,049 were not patent-eligible, and had granted a Rule12(b)(6) motion to dismiss. Representative claim 2 of the ’049 patent recites: A primary station for use in a communications system comprising at least one secondary station, wherein means are provided for broadcasting a series of inquiry messages, each in the form of a plurality of predetermined data fields arranged according to a first communications protocol, and for adding to each inquiry message prior to transmission an additional data field for polling at least one secondary station. The district court held claims of the ’049 patent ineligible as “directed to the abstract idea of ‘additional polling in a wireless communication system,’” without a saving inventive concept, by analogizing to “data manipulation claims” found ineligible in Two-Way Media Ltd. v.… Read More »Uniloc Communications System Patent Survives § 101 Challenge Based on Technical Improvement: Uniloc USA, Inc. v. LG Electronics USA, Inc.