UNILOC USA, INC. v. LG ELECTRONICS USA, INC.

UNILOC USA, INC. v. LG ELECTRONICS USA, INC., Appeal No. 2019-1835 (Fed. Cir. April 30, 2020).  Before Moore, Reyna, and Taranto.  Appealed from N.D. Cal. (Judge Koh).  (Patent Eligibility)

Background:

Uniloc sued LG for infringing a patent directed to an improved communication system between a primary station (such as a base station) and at least one secondary station (such as a mobile device).  Conventionally, primary stations broadcast inquiry messages to invite new devices to join a network and separately conduct polling to parked devices (devices that are already connected but not currently having an active communication) to check if there is any data for transmission.  The patented system improved such systems by allowing the primary stations to add an additional data field as part of an inquiry message, enabling the primary stations to send inquiry messages and conduct polling simultaneously.  This change reduced latency experienced by the parked devices.

LG moved to dismiss Uniloc’s infringement claim under Fed. R. Civ. P. 12(b)(6), arguing that the asserted claims are ineligible under 35 U.S.C. §101 as being directed to an abstract idea and not reciting an inventive concept.  The district court granted LG’s motion.  Uniloc appealed.

Issue/Holding:

Did the district court err in finding the claims ineligible under §101?  (continue reading)

Summary byAshley Yeum

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