Federal Circuit Upholds Two Courts’ Findings that Remote Training Patents are Ineligible

The United States Court of Appeals for the Federal Circuit (CAFC) today announced that Riggs Technology Holdings, Inc.’s US Patent No. 7,299,067 for distance education and training systems is “clearly drawn to abstract ideas.” Judge Chen made both opinions.

Riggs sued Cengage Learning, Inc. in the United States District Court for the District of Massachusetts for infringement of the ‘067 patent, but the district court granted Cengage’s motion to dismiss based on ineligibility of the patent. The court found that the patent was “clearly based on an abstract idea,” and found that “the concept underlying the claims of the ‘067 patent — providing, managing, and/or Document – is similar to these patents.” It was found in claims that the Court of Appeals for the Federal Circuit deemed abstract and ineligible. “

the same as Killian

In its discussion, the Federal Circuit held that the patent’s representative claim 1 is directed to “a method of managing remotely completed training on a handheld device,” followed by seven steps, “to administer training.” It describes an abstract mental process that manages.” Served remotely. Riggs attempted to argue that the claims addressed problems rooted in computer technology for solving problems in the domain of computer networks, but the Federal Circuit argued that the claimed technology was merely “abstract.” It merely provides a “conduit for sensible ideas,” he said. Provide technical solutions to specific technical problems. The Federal Circuit has in Killian As a precedent for that analysis:

“In the Killian case, we made a claim that referred to a ‘search algorithm for identifying qualified persons.’ [Social Security Disability Insurance] The benefits they did not receive were ‘directed to’ [a] Patent ineligible abstract mental process”…explained that “the claim must fail” Alice/May The first steps towards collecting information, making sense of the information collected, and displaying the results, all take place on a typical computer network that behaves in a normal and expected manner. “

Like KillianRiggs’ claim 1 covers the use of general computers to collect and store information, the court said.

towards Alice/May As to Step 2, the Court of Appeals also said that the claims merely directed practitioners to perform abstract steps on a generic computer. KillianA key inventive concept referred to in the Riggs patent is to conduct remote training on a handheld device such as a cell phone, but the CAFC stated that the Supreme Court explained in Alice: rice field. not sufficient for patent eligibility. Neither the specification nor the claims indicate that the procedure set forth in claim 1 is intended to be completed by anything other than “well-understood techniques used in routine and conventional ways.” The court said it used clarifying language. Even step 2 failed.

May be dismissed under 12(b)(6)

Finally, Riggs argues that whether the claims cover prior art relies on an analysis of the facts not done at this preparatory stage, and therefore decides to file litigation at the Rule 12(b)(6) stage. argued that it should not be dismissed. However, the CAFC states: Aatrix Software, Inc. v. Green Shades Software, Inc.Said, “[w]e. eligibility of a patent can be determined at the Rule 12(b)(6) stage “if there are no allegations of fact that would preclude resolving the question of eligibility as a matter of law”. I decided. Because the specification clearly recognizes that the additional claim elements are routine and customary, the court found that “it would be difficult, if not impossible, for a patentee to demonstrate a true dispute. added, 12(b)(6) stage.

In a separate action filed by Riggs against Vagaro, Inc. for the Northern District of California, alleging infringement of the same patent, the same panel of the CAFC decided, on the grounds set forth in the above appeal, We have dismissed Riggs’ appeal as frivolous.

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Author: Alex Milos