IP Law Daily Claims directed to generic data analysis and display functions not patent-eligible
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Wednesday, April 19, 2017

Claims directed to generic data analysis and display functions not patent-eligible

All 81 claims of various patents asserted by inventorship and patent licensing company West View Research, LLC ("WVR") in an infringement suit against automobile manufacturers were ineligible for patent protection under 35 U.S.C. §101 because they were directed to an abstract idea and lacked an inventive concept, the U.S. Court of Appeals for the Federal Circuit has held. The claims were directed to no more than receiving or collecting data queries, analyzing the data query, retrieving and processing the information constituting a response to the initial data query, and generating a visual or audio response to the initial data query. The claims recited conventional elements at a high level of generality. Dismissal of the infringement claims against the auto makers was affirmed (West View Research, LLC v. Audi AG, April 19, 2017, Wallach, E.).

Patents-in-suit. WVR filed a patent infringement suit against auto makers Audi, Volkswagen, Hyundai, Nissan, and Tesla. The patents-in-suit shared a written description and generally disclosed a system and subsystems that used computer hardware, software, and peripheral devices to collect, organize, and display information. WVR stated that claim 63 of U.S. Patent No. 8,719,038 ("the ’038 patent"), titled "Computerized information and display apparatus," and claim 29 of U.S. Patent No. U.S. Patent No. 8,065,156 ("the ’156 patent"), titled "Adaptive information presentation apparatus and methods," were representative of all asserted claims for purposes of the Section 101 analysis.

Claim 63 of the ’038 patent indirectly depended from independent claim 54. Independent claim 54 recited a "computerized apparatus capable of interactive information exchange with a human user" via "a microphone," "one or more processors," a "touch-screen input and display device," a "speech synthesis apparatus" with "at least one speaker," an "input apparatus," and a "computer program" that receives the user’s input and generates an audible or visual result. Claim 63 added an additional limitation that allowed the results to be wirelessly transmitted to a mobile device and allowed the mobile device to configure the data according to parameters specific to the user.

Claim 29 of the ’156 patent indirectly depended from independent claim 25. Independent claim 25 recited a computer readable apparatus that can "receive input from a user via … function keys," "forward the input to a remote networked server for determination of … [the] context associated" with the user’s input and "selection of advertising content," and "present the received content" to the user. Dependent claim 29 added an additional limitation that tailored the available function keys based on the user’s selection relating to a topical area.

Abstract idea. Both claims recited an abstract idea, according to the court. The claims did not go beyond receiving or collecting data queries, analyzing the data query, retrieving and processing the information constituting a response to the initial data query, and generating a visual or audio response to the initial data query. Collecting information, analyzing it, and displaying certain results of the collection and analysis constituted a familiar class of claims directed to a patent-ineligible concept. The claims were not focused on an improvement to computer technology itself.

Inventive concept. Additionally, both claims lacked an inventive concept that would make them patent-eligible. The computer components involved in the arrangements described by the patent claims were generic. The claims recited conventional elements at a high level of generality. Accordingly, the claims were patent-ineligible under Section 101.

The case is Nos. 2016-1947, 2016-1948, 2016-1949, and 2016-1951.

Attorneys: Adam Spencer Garson (Gazdzinski & Associates, PC) for West View Research, LLC. Garland Stephens (Weil, Gotshal & Manges LLP) for Audi AG, Volkswagen AG, Volkswagen Group of America, Inc. dba Audi of America, Tesla Motors, Inc.; Hyundai Motor Company, Ltd., Hyundai Motor America, Inc., Hyundai Motor Manufacturing Alabama, LLC, Nissan Motor Company, Ltd., and Nissan North America, Inc.

Companies: West View Research, LLC; Audi AG; Volkswagen AG; Volkswagen Group of America, Inc. d/b/a Audi of America, Inc.; Tesla Motors, Inc.; Hyundai Motor Company, Ltd.; Hyundai Motor America, Inc.; Hyundai Motor Manufacturing Alabama, LLC; Nissan Motor Company, Ltd.; Nissan North America, Inc.

MainStory: TopStory Patent TechnologyInternet FedCirNews

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