Electric Power Group, LLC v. Alstom S.A.
830 F.3d 1350
| Fed. Cir. | 2016Background
- Electric Power Group (EPG) sued Alstom in the Central District of California for infringement of claims in three patents (ʼ843, ʼ259, ʼ710) that describe real-time wide-area power‑grid monitoring: collecting synchronized phasor and other data from multiple sources, analyzing it, and displaying results.
- Claim 12 of the ʼ710 patent was treated as representative; it recites receiving multiple real-time synchronized data streams and other grid/non-grid data, detecting/analyzing events and dynamic stability metrics, updating measurements in real time, displaying concurrent visualizations, and deriving a composite reliability indicator.
- The district court granted summary judgment for Alstom, holding the asserted claims ineligible under 35 U.S.C. § 101 as directed to the abstract idea of collecting, analyzing, and displaying information from disparate sources and lacking an inventive concept.
- On appeal, EPG did not meaningfully defend claims beyond the representative claim; the Federal Circuit reviewed the § 101 ruling de novo.
- The Federal Circuit held the claims are directed to an abstract idea (information collection, analysis, display) and that the claim elements—limited to the power‑grid context and using generic computers/networks/displays—do not supply an inventive concept sufficient to render them patent‑eligible.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the asserted claims are directed to patent‑eligible subject matter under § 101 | Claims improve real‑time grid monitoring; specify concrete data types and results tied to power‑grid problems | Claims are abstract: they merely collect, analyze, and display information from multiple sources using generic computers | Held ineligible: claims directed to abstract idea of information collection/analysis/display |
| Whether claim elements supply an "inventive concept" to transform the abstract idea into patent‑eligible application | Limiting to power‑grid data and requiring real‑time, synchronized visualization renders claims inventive | Limitations are field‑of‑use and use conventional, off‑the‑shelf computer/network/display technology; no new data sources, devices, or inventive programming | Held insufficient: no nonconventional components or inventive arrangement; merely result‑focused functional claiming fails § 101 |
Key Cases Cited
- Alice Corp. v. CLS Bank Int’l, 134 S. Ct. 2347 (Sup. Ct. 2014) (two‑step framework for abstract ideas and inventive concept)
- Mayo Collaborative Servs. v. Prometheus Labs., Inc., 132 S. Ct. 1289 (Sup. Ct. 2012) (limits on patenting laws of nature and abstract ideas)
- Enfish, LLC v. Microsoft Corp., 822 F.3d 1327 (Fed. Cir. 2016) (claims directed to a specific improvement in computer functionality can be § 101‑eligible)
- TLI Commc’ns LLC v. AV Automotive, 823 F.3d 607 (Fed. Cir. 2016) (collecting and organizing information as abstract idea)
- Internet Patents Corp. v. Active Network, Inc., 790 F.3d 1343 (Fed. Cir. 2015) (information‑collection claims are abstract)
- Content Extraction & Transmission LLC v. Wells Fargo Bank, Nat’l Ass’n, 776 F.3d 1343 (Fed. Cir. 2014) (presenting results of abstract processes is itself abstract)
- Digitech Image Techs., LLC v. Elecs. for Imaging, Inc., 758 F.3d 1344 (Fed. Cir. 2014) (analyzing information by mathematical algorithms as abstract)
- CyberSource Corp. v. Retail Decisions, Inc., 654 F.3d 1366 (Fed. Cir. 2011) (decision‑making based on collected data is abstract)
- Diamond v. Diehr, 450 U.S. 175 (Sup. Ct. 1981) (distinguishing patentable applications of processes from unpatentable abstract ideas)
- Bilski v. Kappos, 561 U.S. 593 (Sup. Ct. 2010) (business‑method patentability limits)
- buySAFE, Inc. v. Google, Inc., 765 F.3d 1350 (Fed. Cir. 2014) (implementing an abstract idea on generic computers is insufficient)
- DDR Holdings, LLC v. Hotels.com, L.P., 773 F.3d 1245 (Fed. Cir. 2014) (claims that effect a specific website display solution may confer eligibility)