Core Wireless Licensing S.A.R.L. v. LG Electronics, Inc. – §101 patent eligible

On January 25, 2018, the United States Court of Appeals for the Federal Circuit (“the Federal Circuit”) released its opinion in Core Wireless Licensing S.A.R.L. v. LG Electronics, Inc., affirming the U.S. District Court for the Eastern District of Texas decisions: (1) to deny summary judgment that four claims from Core Wireless”™ patents are directed to patent ineligible subject matter; (2) to deny judgment as a matter of law that another patent anticipates the asserted claims; and (3) to deny judgment as a matter of law that the asserted claims are not infringed.

Core Wireless Licensing S.A.R.L (“Core Wireless”) sued LG Electronics, Inc. (“LG”) in the Eastern District of Texas, alleging LG infringed dependent claims 8 and 9 of U.S. Patent No. 8,713,476 (“the ”²476 Patent”) and claims 11 and 13 of U.S. Patent No. 8,434,020 (“the ”²020 Patent”). Both patents, owned by Core Wireless, disclose display interfaces that “allow a user to more quickly access desired data stored in, and functions of applications included in, the electronic devices.” Op. at 3. 

Subsequently, LG moved for summary judgment for invalidity of the four asserted claims under 35 U.S.C. § 101. The District Court denied the summary judgment, holding that the claims were not directed to an abstract idea. The District Court reasoned that the interface required a device to be displayed on.  During trial, the District Court ruled that “un-launched state” means “not displayed” and “reached directly” means “reached without an intervening step.” With these constructions, the jury found all asserted claims infringed and not invalid.  LG then moved for judgment as a matter of law for noninfringement. LG argued that the “un-launched state” limitation means “not running” and that the “reached directly” limitation required user interaction with the main menu, and with using those constructions, the jury would have reasonably found for noninfringement. The District Court denied LG”™s motion, as LG did not preserve its claim construction arguments in a Rule 50(a) motion and its second argued claim construction would have made no difference in the outcome. LG also moved for judgment as a matter of law for invalidity, arguing that U.S. Patent No. 6,415,164 (“the ”²164 Patent”) anticipated Core Wireless”™ patents. The District Court denied LG”™s motion for judgment as a matter of law for invalidity as well. LG appealed.

The Federal Circuit began its analysis by determining that the asserted claims are not directed to an abstract idea. The Federal Circuit provided that the claims disclosed an improved user interface for electronic devices and essentially described “a specific manner of displaying a limited set of information to the user,” which improved the speed and functionality of the user interface for electronic devices. Since the Federal Circuit found that the asserted claims were not abstract based on this understanding, the Federal Circuit did not need to move on to part two of the Alice test. Thus, the asserted claims were patent eligible.

The Federal Circuit then disagreed with LG”™s argument that the ”²164 Patent anticipated both the ”²476 Patent and the ”˜020 Patent, using LG”™s expert testimony to conclude that the ”²164 Patent did not disclose any of the limitations disclosed in either of Core Wireless”™ patents. Finally, the Federal Circuit rejected both of LG”™s noninfringement arguments. The Federal Circuit sided with the District Court and found no error in the District Court”™s constructions of the two limitations, “un-launched state” and “reached directly.” The Federal Circuit further found that the specification and the prosecution history more supported the District Court”™s constructions than LG”™s constructions. Finding no error in the claim construction process, the Federal Circuit concluded that substantial evidence supported the jury”™s finding of infringement.