Uniloc USA, Inc. v. Lg Electronics USA, Inc., 957 F.3d 1303

Uniloc sued LG for infringing U.S. Patent No. 6,993,049, which claims a primary-station improvement in wireless communications (described with Bluetooth/piconet examples).
Prior art Bluetooth piconets require separate inquiry and page procedures and polling, causing delays (seconds to tens of seconds) for secondary devices—especially battery‑saving "parked" devices.
The ’049 patent (representative Claim 2) adds a polling data field to each inquiry message so inquiry and polling occur simultaneously, reducing latency for secondary stations.
LG moved to dismiss under Rule 12(b)(6) arguing the claims are patent-ineligible under 35 U.S.C. § 101 as directed to an abstract idea; the district court granted the motion.
The Federal Circuit reviewed de novo and reversed, holding the claims are directed to a patent-eligible improvement in communication system functionality (reduced latency) and remanded.

Issue	Plaintiff's Argument	Defendant's Argument	Held
§101 eligibility — are the claims directed to an abstract idea?	Claims are directed to a concrete improvement: adding a polling field to inquiry messages to reduce latency for parked secondary stations.	Claims merely recite additional polling/data manipulation in conventional wireless messages and use generic Bluetooth components, so are abstract.	Court: Eligible. Claims are directed to a non‑abstract improvement in communication-system functionality (latency reduction).
Does compatibility with conventional systems or lack of explicit physical components render the claims abstract?	Compatibility and lack of physical-structure language do not make a software/network improvement abstract; software can effect patentable improvements.	The claims’ compatibility and result-based functional language show they are generalized and thus ineligible.	Court: Not dispositive. Compatibility and absence of physical terms do not defeat eligibility when claim improves computer/network operation.

Alice Corp. v. CLS Bank Int’l, 573 U.S. 208 (2014) (establishes two-step test for § 101)
Assoc. for Molecular Pathology v. Myriad Genetics, Inc., 569 U.S. 576 (2013) (laws of nature/natural phenomena/abstract ideas not patentable)
DDR Holdings, LLC v. Hotels.com, L.P., 773 F.3d 1245 (Fed. Cir. 2014) (claims directed to a network-specific technological improvement held eligible)
Enfish, LLC v. Microsoft Corp., 822 F.3d 1327 (Fed. Cir. 2016) (self-referential database as an improvement to computer functionality)
Visual Memory LLC v. NVIDIA Corp., 867 F.3d 1253 (Fed. Cir. 2017) (claims addressing processor accommodation and performance held eligible)
Digitech Image Techs., LLC v. Electronics for Imaging, Inc., 758 F.3d 1344 (Fed. Cir. 2014) (data-gathering/combining claims held abstract)
Two-Way Media Ltd. v. Comcast Cable Commc’ns, LLC, 874 F.3d 1329 (Fed. Cir. 2017) (claims reciting generic packet-transmission steps held ineligible)
Ancora Techs., Inc. v. HTC America, Inc., 908 F.3d 1343 (Fed. Cir. 2018) (claims solving a specific computer-security vulnerability held eligible)
Data Engine Techs. LLC v. Google LLC, 906 F.3d 999 (Fed. Cir. 2018) (claims improving navigation of complex spreadsheets held eligible)
Core Wireless Licensing S.A.R.L. v. LG Electronics, Inc., 880 F.3d 1356 (Fed. Cir. 2018) (improved UI for small screens held eligible)
Finjan, Inc. v. Blue Coat Sys., Inc., 879 F.3d 1299 (Fed. Cir. 2018) (behavior-based virus detection as improvement to computer security)