The United States Court of Appeals for the Federal Circuit ruled last Thursday that four patents owned by ChargePoint, Inc., are invalid. The patents are directed to a networked electric vehicle charging station (EVCS) and were previously held invalid by a federal court in Maryland for claiming inventions that are ineligible for patent protection. ChargePoint had appealed that holding to the Federal Circuit.
As previously reported by this blog, ChargePoint sued rival EVCS provider SemaConnect, Inc., in December 2017 for alleged infringement of the four ChargePoint patents. ChargePoint sought a restraining order from the Maryland court to prevent SemaConnect from installing some $16 million of ECVS’s purchased by Electrify America, the Volkswagen subsidiary that has pledged to spend $2 billion on EV infrastructure as part of the settlement agreement for Volkswagen’s diesel emissions scandal. Instead of ordering SemaConnect to delay installation of the EVCS’s, the Maryland court held ChargePoint’s patents to be invalid and dismissed the case altogether.
On appeal, ChargePoint sought to convince a panel of three appellate judges at the Federal Circuit that the claimed inventions are eligible to be patented. At issue is a rule of patent law that bars the patenting of “abstract ideas.” The Maryland court had found the claimed inventions to be no more than the abstract idea of remotely controlling an EVCS by connecting it to a network.
In a dense legal opinion, the Federal Circuit evaluated the claims of the four ChargePoint patents under the Supreme Court’s framework for evaluating patent eligibility, which is called the Mayo/Alice inquiry after some of the leading cases on this subject. While acknowledging that “the inventors here had the good idea to add networking capabilities to existing charging stations to facilitate various business transactions,” the Federal Circuit ultimately determined that the claimed inventions of the four ChargePoint patents were no more than patent ineligible abstract ideas. Specifically, the Federal Circuit found the patent claims to be directed to “nothing more than the abstract idea of communication over a network for interacting with a device, applied to the context of electric vehicle charging stations.”
The case will now be returned to the federal court in Maryland where ChargePoint initially sued SemaConnect. That court is expected to dismiss the case.