Digest of Digitech Image Techs., LLC v. Elecs. For Imaging, Inc., No. 2013-1600, -1601, -1602, -1603, -1604, -1605, -1606, -1607, -1608, -1609, -1610, -1611, -1612, -1613, -1614, -1615, -1616, -1617, -1618 (Fed. Cir. July 11, 2014) (precedential). On appeal from C.D. Cal. Before Moore, Reyna, and Hughes.

Procedural Posture: Plaintiff appealed district court’s finding of invalidity under 35 U.S.C. § 101. CAFC affirmed.

  • Patent Eligibility (Section 101): The district court did not err in finding that the claimed “device profile,” described as a collection of information, is ineligible subject matter under § 101 because it is not a tangible or physical thing and does not fall within any of the categories of eligible subject matter.
  • Patent Eligibility (Section 101): The district court did not err in finding the asserted method claims ineligible under § 101 because they describe a broad abstract process of organizing information not tied to a physical structure or machine. The method claims are too broad without further limitations, and the lone mention of an image reproduction system in the preamble does not limit claim scope when it merely states the invention’s purpose or intended use.

Hui Li