Monthly Archives: March 2019

CHARGEPOINT, INC. v. SEMACONNECT, INC., decided March 28, 2019, Statutory Subject Matter

U.S. Patent Nos. 8,138,715, 8,432,131, 8,450,967, and 7,956,570 are directed to networked charging stations for electric vehicles (pages 2-5).  For step one in patent eligibility consideration, communicating requests to a remote server and receiving a response is an abstract idea (page 9).  The claim must be directed to that abstract idea to be abstract (page […]

ARCTIC CAT INC., v. GEP POWER PRODUCTS, INC., decided March 26, 2019, Preamble Limitation

U.S. Patent Nos. and 7,420,822 are directed to electrical-connection boxes with an array of openings (page 2).  One preamble recites “a power distribution module for a personal recreational vehicle” (pages 4-5 and 6-7).  Since the body of the claims describe structurally complete inventions (power modules), the vehicle recitation of the preamble is only an intended […]

SRI INT’L, INC. v. CISCO SYS., INC., decided March 20, 2019, Statutory Subject Matter

U.S. Patent Nos. 6,484,203 and 6,711,615 are directed to network intrusion detection (pages 2-3).   The claims directed to computer network monitoring are necessarily rooted in computer technology to solve a specific problem in the realm of computer networks (page 8).  The claims recite a plurality of network monitors that monitor for specific types of data […]

NATURAL ALTERNATIVES INTL. v. CREATIVE COMPOUNDS, LLC, decided March 15, 2019, Statutory Subject Matter

U.S. Patent Nos. 5,965,596, 7,825,084, 7,504,376, 8,993,610, 8,470,865, and RE45,947 are directed to dietary supplements containing beta-alanine (pages 2-3).  The claims recite “effective to increase beta-alanylhistidine dipeptide synthesis in the human tissue,” which is interpreted to elevate beta-alanine above natural levels to cause an increase in synthesis in tissue, and “dietary supplement,” which is interpreted […]

FOREST LABORATORIES, LLC v. SIGMAPHARM LABORATORIES, LLC, decided March 14, 2019, Claim Interpretation

U.S. Patent No. 5,763,476 is directed to Saphris, an antipsychotic drug.  The limitation of claim 1 of “the composition is a solid composition and disintegrates within 30 seconds in water at 37 degrees C” was limited by the district court to sublingual or buccal formulations, which is a limitation of dependent claim 4 (pages 4-5).  […]

PERSONAL WEB TECHNOLOGIES, LLC v. APPLE, INC., decided March 8, 2019, Obviousness

U.S. Patent No. 7,802,310 is directed to licensing using unique identifiers for computer files based on content of the files (pages 2-4).  Prior art Woodhill stores three levels of information including a highest level of a file name and location and a lowest level storing a binary object hash including a binary object identifier based […]