Patent claims found to not be directed to patent eligible subject matter
TLI Communications LLC v. AV Automotive, L.L.C., No. 2015-1372 (Fed. Cir. May 17, 2016)
TLI Communications appealed the Eastern District of Virginia’s decision that its patent failed to claim patent-eligible subject matter under 35 U.S.C. 101 because the claims were directed to an abstract idea. On review, the Federal Circuit ultimately held that the patent was directed to the abstract idea of classifying and storing digital images in an organized manner, and failed to add an inventive concept sufficient to confer patent eligibility.
Under Step 1 of the Supreme Court's Alice test, the court noted that representative claim 17 was drawn to the concept of classifying an image and storing the image based on its classification and that while claim 17 required concrete, tangible components such as “a telephone unit” and a “server,” the specification made clear that the recited physical components merely provided a generic environment in which to carry out the abstract idea of classifying and storing digital images in an organized manner. The court found that the inventor sought to “provid[e] for recording, administration and archiving of digital images simply, fast and in such a way that the information therefore may be easily tracked,” but the claims attaching classification data, such as dates and times, to images for the purpose of storing those images in an organized manner was a well-established “basic concept” when considered under Alice Step 1. The court also stated that even though the claims limited the abstract idea to a particular environment—a mobile telephone system—that did not make the claims any less abstract for the Step 1 analysis.
Under Alice Step 2, the court agreed with the district court’s decision that the claims’ recitation of a “telephone unit,” a “server,” an “image analysis unit,” and a “control unit” failed to add inventive concept sufficient to bring the abstract idea into the realm of patentability.