CHAMBERLAIN GROUP, INC. v. TECHTRONIC INDUSTRIES CO. LTD., decided August 21, 2019, Statutory Subject Matter

U.S. Patent No. 7,224,275 is directed to wirelessly communicating information about a moveable barrier (door) (pages 3-4). The only difference between the prior art and claim 1 is that the communication of status information is wireless rather than wired (pages 5-6). The controller, interface, and wireless transmitter of claim 1 are described in the specification as “well understood in the art” (page 9). Each element is well understood and all the steps as an ordered combination add nothing not already present when considered separately (pages 9-10). None of the other claim elements may be regarded as inventive (page 10).

Hindsight: It may be best not to characterize any aspect or device as “well understood.” 112 does not require this. Instead, the devices may be characterized as specific hardware configured to make the novel functionality work. In this case, a fall back position for some way in which the devices are altered or operate differently to allow for wireless communication in this barrier context may have been helpful.