114 F. Supp. 3d 614
N.D. Ill.2015Background
- Chamberlain is a Connecticut corporation with Elmhurst, Illinois headquarters, selling garage door openers and related accessories.
- Nortek Security & Control LLC is a California company offering products in security-related industries, including access control.
- Chamberlain filed suits in 2014 alleging Nortek infringed the '977, '212, and 'Oil patents, later adding the '923 and '218 patents.
- Nortek moved to dismiss under Rule 12(b)(6) for patent-eligible subject matter under 35 U.S.C. § 101.
- The court has jurisdiction under 28 U.S.C. §§ 1331 and 1338(a).
- The case centers on whether the asserted patents are patent-eligible under § 101 and applicable case law.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Is the '977 Patent patent-eligible under §101? | '977 claims are physical, networked components improving a garage-door system. | Claims describe an abstract idea of opening/closing a barrier. | Yes; '977 claims are patent-eligible. |
| Are the Alarm System Patents patent-eligible under §101? | Patents integrate mechanical/electrical components with secure communications. | Patents recite abstract concept of system integration without invention. | Yes; Alarm System Patents are patent-eligible. |
| Do the claims include an inventive concept beyond abstract idea? | Claims add machine/interaction elements tied to specific devices. | Simply using a computer network with an abstract idea. | Yes; claims contain an inventive concept. |
| Do the machine-or-transformation aspects support eligibility? | Claims tied to a movable barrier operator and controller. | Not more than an abstract concept with generic components. | Yes; machine-or-transformation test supports eligibility. |
Key Cases Cited
- Alice Corp. Pty. Ltd. v. CLS Bank Int’l, 134 S. Ct. 2347 (2014) (abstract ideas not patentable; limit to applications)
- Mayo Collaborative Servs. v. Prometheus Labs., Inc., 132 S. Ct. 1289 (2012) (two-step framework for §101, inventive concept needed)
- Diamond v. Diehr, 450 U.S. 175 (1981) (integration of math/algorithm with a known structure may be patent-eligible)
- Ultramercial, Inc. v. Hulu, LLC, 772 F.3d 709 (Fed. Cir. 2014) (use of the Internet alone is not enough to save abstract claims)
- Content Extraction & Transmission LLC v. Wells Fargo Bank, Nat’l Ass’n, 776 F.3d 1343 (Fed. Cir. 2014) (no inventive concept in generic scanner performing routine activities)
- In re Bilski, 545 F.3d 943 (Fed. Cir. 2008) (machine-or-transformation test as a clue for process eligibility)