Core Wireless Licensing v. LG Electronics, Inc., Case No. 2016-2684 (Fed. Cir. January 25, 2018)
In Core Wireless Licensing v. LG Electronics, Inc., the Federal Circuit held that claims directed to an improved user interface for computing devices were patent-eligible under 35 U.S.C. § 101.
The court delineated the two-step framework of Alice that requires 1) a determination as to whether the claims are "directed to" a patent-ineligible concept, and, if they are, then 2) a determination as to whether the additional elements of the claims transform the nature of the claim into a patent-eligible application.
The court noted that "[a]t step one, we must articulate what the claims are directed to with enough specificity to ensure the step one inquiry is meaningful.”
First, the court looked to various limitations of the representative claim, and indicated that those limitations "specif[y] a particular manner by which the summary window must be accessed," "restrain the type of data that can be displayed in the summary window," and "require that the device applications exist in a particular state."
The court noted that the foregoing limitations "disclose a specific manner of displaying a limited set of information to the user, rather than using conventional user interface methods to display a generic index on a computer."
Analogizing the invention to the improved systems in Enfish, Thales, Visual Memory, and Finjan, the court noted that the claims recite a specific improvement over prior systems and result in an improved user interface for electronic devices.
Next, the court noted that the specification identifies various deficiencies of prior art user interfaces relating to efficient functioning of computing devices. For example, the court noted that prior art systems required a user to navigate through many different layers or views to access desired data or functionality, and that that process could "seem slow, complex and difficult to learn."
In contrast, the court noted that the disclosed invention improves the efficiency of using the electronic device by permitting a limited list of common functions and commonly accessed stored data to be accessed directly from a main menu. The court noted several benefits, such as an improvement in the speed of a user's navigation through views and windows, a reduction in the number of steps to reach desired data or functionality, and the ability of a user to identify data or functionality of an application without actually opening the application.
The court held that the claims were directed to an improvement in the functioning of computers, particularly those with small screens, and were not directed to an abstract idea. In turn, the court did not proceed to step two of the Alice test.