Tranxition, Inc. v. Lenovo (United States) Inc.
664 F. App'x 968
| Fed. Cir. | 2016Background
- Tranxition sued Lenovo (and separately Micro Focus) asserting patents ’877 and its continuation ’766, which claim automated migration/transition of user configuration settings from one computer to another.
- The patents describe providing configuration information, generating extraction and transition plans, extracting settings, and converting formats for the target system.
- Lenovo moved for summary judgment under Rule 56, arguing all asserted claims are invalid under 35 U.S.C. § 101 as directed to an abstract idea.
- The district court held the claims were directed to the abstract idea of migrating configuration settings and lacked an inventive concept; it granted summary judgment for Lenovo. Micro Focus later obtained judgment on the pleadings based on preclusion.
- Tranxition appealed; the Federal Circuit reviewed de novo and affirmed, concluding the claims are patent-ineligible under § 101.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the claims are directed to patent‑ineligible subject matter under § 101 | Claims are directed to a specific software‑based solution (“transitioning”) improving computer functionality, not an abstract idea | Claims are directed to the abstract idea of migrating/transitioning settings between computers | Claims are directed to the abstract idea of migration/transitioning of settings (Alice step 1) |
| Whether the claims contain an "inventive concept" under Alice step 2 | Automated process captures settings differently than a manual process and thus is inventive | Claim steps are routine, generic computer implementation of the abstract idea | No inventive concept; steps are conventional computer implementation and insufficient to confer eligibility |
| Whether presumption of validity / clear and convincing standard applies to § 101 challenges | District court erred by treating presumption as inapplicable and not using clear and convincing standard | District court treated § 101 as not subject to presumption (district relied on concurring opinion) | Court declined to decide the evidentiary standard here (no material facts in dispute) and affirmed invalidity regardless |
| Appropriateness of summary judgment on § 101 | Genuine factual disputes about operation vs manual migration warrant denial | No material factual disputes; legal question reviewed de novo supports summary judgment | Summary judgment proper; claims invalid as matter of law |
Key Cases Cited
- Alice Corp. Pty. Ltd. v. CLS Bank Int’l, 134 S. Ct. 2347 (framework for determining patent‑eligibility under § 101)
- Ass’n for Molecular Pathology v. Myriad Genetics, Inc., 133 S. Ct. 2107 (laws of nature, natural phenomena, and abstract ideas are not patentable)
- Enfish LLC v. Microsoft Corp., 822 F.3d 1327 (relevant inquiry whether claims improve computer functionality)
- Digitech Image Techs., LLC v. Elecs. For Imaging, Inc., 258 F.3d 1344 (claims that merely automate abstract ideas are ineligible)
- Ultramercial, Inc. v. Hulu, LLC, 772 F.3d 709 (routine, conventional computer activities do not supply inventive concept)
- In re TLI Commc’ns LLC Patent Litig., 823 F.3d 607 (application of Alice two‑step analysis to claims implemented on computers)