Sensormatic Electronics, LLC v. Wyze Labs, Inc.
20-2320
| Fed. Cir. | Jul 14, 2021Background
- Sensormatic sued Wyze asserting five patents (’534, ’370, ’129, ’019, ’772) covering a wireless surveillance system; 25 claims were ultimately asserted.
- Representative claim: ’129 claim 14 describes a surveillance system with at least two wireless input capture devices (ICDs) that (1) have sensors/processors/memory/transceivers, (2) directly cross-communicate wirelessly without a remote server, and (3) communicate with a remote viewing device.
- Wyze moved for judgment on the pleadings under Rule 12(c), arguing the claims are patent-ineligible under 35 U.S.C. § 101; the district court agreed and held the claims were directed to abstract ideas and lacked an inventive concept.
- The Federal Circuit applied the Supreme Court’s Alice two-step framework: (1) are the claims directed to an abstract idea; (2) if so, do they recite an inventive concept that transforms the claim into patent-eligible subject matter.
- Sensormatic argued the claims recite specific, nonabstract improvements (ICD configuration, dual encoding, and trigger-event prioritization); Wyze argued the claims are the abstract ideas of wireless communication and remote surveillance implemented with conventional components.
- The Federal Circuit affirmed: claims were directed to abstract ideas (wireless communication/remote surveillance) and did not recite an inventive concept beyond generic computer components; claim 14 was a proper representative claim.
Issues
| Issue | Sensormatic's Argument | Wyze's Argument | Held |
|---|---|---|---|
| Whether claims are directed to an abstract idea (Alice step 1) | Claims are directed to concrete technological improvements: (1) a novel ICD configuration removing need for a central server; (2) dual encoding to save bandwidth/compatibility; (3) trigger-event prioritization for storage | Claims are directed to abstract ideas—wireless communication and remote surveillance—and any claimed details are conventional | Directed to abstract ideas (wireless communication and remote surveillance); Sensormatic’s putative improvements are abstract or not specifically claimed |
| Whether claims recite an inventive concept (Alice step 2) | The claimed ordered configuration of ICDs distributes server functions to devices, extending range and eliminating server—an unconventional, inventive configuration | Claims merely recite abstract ideas implemented with generic, well-known computer components and conventional wireless technologies | No inventive concept: limitations use generic components/techniques; ordered combination not shown to be inventive |
| Whether limitations like dual encoding and trigger events make claims patent eligible | Dual encoding and trigger-event prioritization are specific, inventive features improving bandwidth, compatibility, and storage | Those features are either not central to the claims or are themselves abstract/conventional | Court considered these limitations and found them abstract or conventional; they do not supply eligibility |
| Whether claim 14 may be treated as representative of all asserted claims | Claim 14 is not fully representative; other claims include distinct limitations warranting separate analysis | Claim 14 is representative; patentee failed to show any meaningful distinctive significance of omitted limitations | Claim 14 properly treated as representative; district court also discussed other limitations and Sensormatic did not identify unconsidered features |
Key Cases Cited
- Alice Corp. v. CLS Bank Int'l, 573 U.S. 208 (2014) (announces two-step framework and holds that reciting a generic computer does not make an abstract idea patent eligible)
- Mayo Collaborative Servs. v. Prometheus Labs., Inc., 566 U.S. 66 (2012) (explains that merely appending conventional steps to an abstract idea cannot make it patent eligible)
- Bilski v. Kappos, 561 U.S. 593 (2010) (machine-or-transformation is a useful clue but not dispositive for § 101)
- Chamberlain Grp. v. Techtronic Indus. Co., 935 F.3d 1341 (Fed. Cir. 2019) (holding that the broad concept of communicating information wirelessly is an abstract idea)
- Berkheimer v. HP Inc., 881 F.3d 1360 (Fed. Cir. 2018) (patent eligibility is a legal conclusion that may depend on underlying factual issues; factual findings can affect Alice step two)
- Green v. Fund Asset Mgmt., L.P., 245 F.3d 214 (3d Cir. 2001) (standard for Rule 12(c) judgment on the pleadings; view facts in pleadings in the light most favorable to nonmoving party)