Federal Circuit Summaries

Before Moore, O’Malley, and Wallach. Appeal from the Eastern District of Texas (Judge Gilstrap).

Summary: Claims directed to summarizing and presenting information on display interfaces for electronic devices are patent eligible under 35 U.S.C. § 101 when they are directed to a specific improvement over prior systems rather than an abstract idea.

Core Wireless sued LG alleging infringement of patent claims directed to improved display interfaces, particularly for electronic devices with small screens. The improved interfaces allow a user to more quickly access data and applications in electronic devices. LG moved for summary judgment that the claims constituted patent ineligible subject matter under 35 U.S.C. § 101. The district court found that the claims are not directed to an abstract idea because the concepts in the claims of “application,” “summary window,” and “unlaunched state” are specific to devices like computers and cellphones. Even if the claims were directed to an abstract idea, they would have passed the machine-or-transformation test. The jury found all asserted claims to be infringed and not invalid. LG moved for judgment as a matter of law of non-infringement and anticipation, both of which were denied.

The Federal Circuit affirmed the district court’s denial of summary judgment under 35 U.S.C. § 101 as well as the denials of judgment as a matter of law. The Federal Circuit acknowledged that the generic idea of summarizing information existed prior to the invention. However, the Federal Circuit noted that the claims recite a specific improvement over conventional user interface methods, resulting in an improved user interface for electronic devices. In its analysis, the Federal Circuit pointed to claim limitations that disclose the specific manner of displaying a limited set of information to the user. It also highlighted language in the specification which indicates that the claims are directed to an improvement in the functioning of computers, particularly those with small screens. Because the Federal Circuit held that the asserted claims are not directed to an abstract idea, it did not proceed to the second step of the inquiry under Alice Corp. Pty. v. CLS Bank Int’l, 134 S. Ct. 2347, 2354 (2014). The Federal Circuit also rejected LG’s argument that it was entitled to judgment as a matter of law on anticipation which was based on Core Wireless’ failure to present any affirmative evidence in rebuttal to LG’s anticipation argument. Finally, the Federal Circuit rejected LG’s non-infringement arguments. LG argued that the correct construction of “unlaunched state” should be “not running” rather than “not displayed” and that no reasonable jury could have found that the accused devices satisfy one of the claim limitations.

Judge Wallach dissented in part, arguing that, the district could should have construed “unlaunched state” to mean “not running” as LG proposed, instead of “not displayed.” In his analysis, Judge Wallach pointed to the distinct and independent meanings of “display” and “launch” as used in the claims as well as the specification.