The District Court for the Northern District of California granted LG Electronics’ motion to dismiss an infringement claim brought against the company by Uniloc USA Inc., invalidating the patent at issue. The court found that the patent for a process to speed up communications between Bluetooth devices was abstract, did not include an inventive concept and “merely automates the manual wake-up process” with traditional hardware and techniques. Comparable claims have been found to be abstract in similar cases. Additionally, the court said that the patent was directed to the abstract idea of “additional polling in a wireless communication system, and therefore was determined invalid.