In this case, LG Electronics appealed from a district court decision denying summary judgement that claims 8 and 9 of a software patent, No. 8,713,476 and claims 11 and 13 of another software patent, No. 8,434,020 are directed to patent ineligible subject matter under 35 U.S.C. § 101.
The patents disclose improved display interfaces for electronic devices with small screens like mobile telephones. An application summary window is displayed while a software application is in an unlaunched state.
Claims 8 and 9 of the ’476 software patent depend from claim 1, which recites:
1. A computing device comprising a display screen, the computing device being configured to display on the screen a menu listing one or more applications, and additionally being configured to display on the screen an application summary that can be reached directly from the menu, wherein the application summary displays a limited list of data offered within the one or more applications, each of the data in the list being selectable to launch the respective application and enable the selected data to be seen within the respective application, and wherein the application summary is displayed while the one or more applications are in an un-launched state.
Claims 11 and 13 of the ’020 patent depend from claim 1, which recites:
1. A computing device comprising a display screen, the computing device being configured to display on the screen a main menu listing at least a first application, and additionally being configured to display on the screen an application summary window that can be reached directly from the main menu, wherein the application summary window displays a limited list of at least one function offered within the first application, each function in the list being selectable to launch the first application and initiate the selected function, and wherein the application summary window is displayed while the application is in an un-launched state.
The district court held that the claims are not directed to an abstract idea because, even crediting LG’s characterization of the claims as directed to “displaying an application summary window while the application is in an unlaunched state,” the concepts of “application,” “summary window,” and “unlaunched state” are specific to devices like computers and cell phones. The district court explained that LG identified no analog to these concepts outside the context of such devices. It further noted even if claim 1 were directed to an abstract idea, it would still be patent eligible at least because it passes the machine-or-transformation test. The jury found all asserted claims infringed and not invalid.
Citing Alice v CLS, the Federal Circuit noted that because patent protection does not extend to claims that monopolize the building blocks of human ingenuity, claims directed to laws of nature, natural phenomena, and abstract ideas are not patent eligible. The Supreme Court instructs courts to distinguish between claims that claim patent ineligible subject matter and those that integrate the building blocks into something more. First, we determine whether the claims at issue are directed to a patent-ineligible concept. If so, we examine the elements of the claim to determine whether it contains an ‘inventive concept’ sufficient to ‘transform’ the claimed abstract idea into a patent-eligible application.
The Federal Circuit stated that, at step one, we must articulate what the claims are directed to with enough specificity to ensure the step one inquiry is meaningful. Thales Visionix Inc. v. United States Although there is difficulty inherent in delineating the contours of an abstract idea, we must be mindful that all inventions at some level embody, use, reflect, rest upon, or apply laws of nature, natural phenomena, or abstract ideas. We also ask whether the claims are directed to a specific improvement in the capabilities of computing devices, or, instead, a process that qualifies as an ‘abstract idea’ for which computers are invoked merely as a tool. Enfish, LLC v. Microsoft Corp. in Enfish, the Federal Circuit held claims reciting a self-referential table for a computer database eligible under step one because the claims were directed to a particular improvement in the computer’s functionality, even though the invention ran on a general purpose computer.
The Federal Circuit indicated that the asserted claims in this case are directed to an improved user interface for computing devices, not to the abstract idea of an index, as argued by LG on appeal.3 Although the generic idea of summarizing information certainly existed prior to the invention, these claims are directed to a particular manner of summarizing and presenting information in electronic devices. Claim 1 of the ’476 patent requires “an application summary that can be reached directly from the menu,” specifying a particular manner by which the summary window must be accessed. The claim further requires the application summary window list a limited set of data, “each of the data in the list being selectable to launch the respective application and enable the selected data to be seen within the respective application.” This claim limitation restrains the type of data that can be displayed in the summary window. Finally, the claim recites that the summary window “is displayed while the one or more applications are in an un-launched state,” a requirement that the device applications exist in a particular state. These limitations disclose a specific manner of displaying a limited set of information to the user, rather than using conventional user interface methods to display a generic index on a computer. Like the improved systems claimed in Enfish, Thales, Visual Memory, and Finjan, these claims recite a specific improvement over prior systems, resulting in an improved user interface for electronic devices.
The specification confirms that these claims disclose an improved user interface for electronic devices, particularly those with small screens. It teaches that the prior art interfaces had many deficits relating to the efficient functioning of the computer, requiring a user “to scroll around and switch views many times to find the right data/functionality.”
Because the Federal Circuit held that the asserted claims are not directed to an abstract idea, they did not proceed to the second step of the inquiry. The claims are patent eligible under § 101.