Core Wireless Licensing S.A.R.L. v. LG Electronics, Inc.
880 F.3d 1356
| Fed. Cir. | 2018Background
- Core Wireless sued LG for infringing dependent claims of U.S. Pat. Nos. 8,713,476 and 8,434,020, which claim an application-summary user interface for small-screen devices that displays a limited list of selectable data/functions reachable directly from a main menu while the application is in an "un-launched state."
- District Court held claim 1 representative for §101 analysis and denied LG's summary judgment motion that the asserted claims were invalid under §101, finding the claims recite a specific improvement in device UI functionality.
- At trial the court construed "un-launched state" as "not displayed" and "reached directly" as "reached without an intervening step;" jury found infringement and no invalidity.
- LG moved for JMOL that Blanchard anticipated the claims and that the accused devices do not infringe; the district court denied both motions.
- On appeal the Federal Circuit affirmed: claims are patent-eligible under §101 (step one), substantial evidence supports denial of JMOL on anticipation, and substantial evidence supports infringement given the court's constructions.
Issues
| Issue | Plaintiff's Argument (Core Wireless) | Defendant's Argument (LG) | Held |
|---|---|---|---|
| §101 patent eligibility | Claims recite a specific UI improvement for small-screen devices (limited summary window reachable from menu while app is un-launched) and thus are not an abstract idea | Claims merely cover the abstract idea of indexing/summarizing information; invoking generic computer components | Held: Claims are directed to a specific improvement in computer functionality and are patent eligible (no need to reach step two) |
| Construction of "un-launched state" | Core: means "not displayed" (can include background-running processes) | LG: should mean "not running" (application not executing) | Held: "un-launched state" = "not displayed"; construction supported by claim language, spec, and prosecution history |
| Anticipation by Blanchard | Core: Blanchard does not disclose the claim limitations (e.g., "limited list") | LG: Blanchard anticipates every element; presented expert testimony as prima facie proof | Held: JMOL denied — reasonable jury could reject LG's expert after cross-examination; presumption of validity not overcome by clear and convincing evidence |
| Infringement ("reached directly from [main] menu") | Core: accused devices’ notification shade is reachable directly from the home screen/status bar and user manual treats status bar as part of home screen | LG: notification shade is reached from status bar which is distinct from main menu, so an intervening step exists | Held: Substantial evidence supports jury finding that status bar is part of main menu and summary is reachable directly; JMOL denied |
Key Cases Cited
- Alice Corp. Pty. v. CLS Bank Int’l, 573 U.S. 208 (Sup. Ct. 2014) (two-step framework for abstract-idea analysis under §101)
- Mayo Collaborative Servs. v. Prometheus Labs., Inc., 566 U.S. 66 (Sup. Ct. 2012) (inventive concept inquiry for §101)
- Enfish, LLC v. Microsoft Corp., 822 F.3d 1327 (Fed. Cir. 2016) (claims directed to specific improvement in computer functionality are patent eligible)
- Thales Visionix Inc. v. United States, 850 F.3d 1343 (Fed. Cir. 2017) (claims to improved sensor utilization not abstract)
- Visual Memory LLC v. NVIDIA Corp., 867 F.3d 1253 (Fed. Cir. 2017) (claims to improved memory system patent eligible)
- Finjan, Inc. v. Blue Coat Sys., Inc., 879 F.3d 1299 (Fed. Cir. 2018) (claims directed to a new kind of file enabling improved security functionality are patent eligible)
- O2 Micro Int’l Ltd. v. Beyond Innovation Tech. Co., 521 F.3d 1351 (Fed. Cir. 2008) (district court duty to resolve fundamental claim-term disputes)
- Teva Pharm. USA, Inc. v. Sandoz, Inc., 574 U.S. 318 (Sup. Ct. 2015) (standard of review for claim construction; subsidiary factual findings reviewed for clear error)
- Phillips v. AWH Corp., 415 F.3d 1303 (Fed. Cir. 2005) (claim construction principles)
- Microsoft Corp. v. i4i Ltd. P’ship, 564 U.S. 91 (Sup. Ct. 2011) (patent validity requires clear and convincing evidence to overcome presumption of validity)