Summary
The United States Court of Appeals for the Federal Circuit affirmed summary judgment that claims in three Electric Power Group patents concerning real-time monitoring, analysis, and display of electric-grid data were ineligible for patenting under 35 U.S.C. § 101. The court held that the claims were directed to the abstract idea of collecting, analyzing, and displaying information and did not add an inventive concept through their use of conventional computer, network, and display technology.
Topics
Practice areas
Questions Presented
- Whether the asserted patent claims were directed to a patent-ineligible abstract idea under 35 U.S.C. § 101.
- Whether the claim elements, individually or as an ordered combination, supplied an inventive concept sufficient to transform the abstract idea into a patent-eligible application.
- Whether the district court properly granted summary judgment of patent ineligibility.
Holdings
- Claims focused on collecting information, analyzing it, and displaying the results, even when limited to particular information content or a particular field such as electric-power-grid monitoring, are directed to an abstract idea when they do not claim a particular inventive technology for performing those functions.
- The asserted claims lacked an inventive concept because they required only the selection, collection, analysis, and display of information using generic, conventional computers, networks, and display devices.
- The district court properly granted summary judgment that the asserted claims were ineligible for patenting under § 101.
Key quotations
“Though lengthy and numerous, the claims do not go beyond requiring the collection, analysis, and display of available information in a particular field, stating those functions in general terms, without limiting them to technical means for performing the functions that are arguably an advance over conventional computer and network technology.” (opinion at 2)
“The claims, defining a desirable information-based result and not limited to inventive means of achieving the result, fail under § 101.” (opinion at 2)
“They are therefore directed to an abstract idea.” (opinion at 8)
“In this case, the district court's wrap-up description confirms its, and our, conclusion that the claims at issue fail to meet the standard for patent eligibility under § 101.” (opinion at 12)
Factual background
Electric Power Group owned three patents describing systems and methods for real-time performance monitoring of electric power grids. The asserted claims required collecting data from multiple grid and non-grid sources, analyzing the data, and displaying event analyses, diagnoses, and grid-reliability information. The claims did not specify a particular inventive technology, device, algorithm, or nonconventional arrangement for performing those functions.
Procedural history
Electric Power Group sued the Alstom defendants for infringement of claims in three patents concerning real-time monitoring of electric power grids. The district court treated claim 12 of the '710 patent as representative and granted Alstom summary judgment of patent ineligibility under § 101. The Federal Circuit had jurisdiction under 28 U.S.C. § 1295(a)(1) and affirmed.