District Court Tackles Patent Eligibility

Tuesday, April 3, 2018

In an opinion addressing patent invalidity under 35 U.S.C. § 101, U.S. District Judge Marvin J. Garbis granted the defendant’s motion to dismiss for failure to state a claim on the ground that the claims of four U.S. patents were directed to patent-ineligible subject matter.  The Court summarized the patents as being directed to methods, systems, and apparatuses for networked electric vehicle (“EV”) charging stations, wherein EV charging stations are connected to a remote server via the Internet to permit, among other things, remote access and control by a user via a cell phone or other electronic device.  In first addressing whether the claims were directed to abstract ideas, the Court stated that “the Federal Circuit has consistently held that gathering, analyzing, transmitting, receiving, filtering, organizing, or displaying data, and combinations thereof, is an abstract idea without something more,” before engaging in a claim-by-claim analysis to find that each of the asserted claims involved combinations of these abstract ideas to operate networks and devices in known and expected ways.  The Court then found that the claims did not add enough to or transform the abstract ideas to the level of a patent-eligible inventive concepts, explaining that the claims recited generic computer and networking equipment and neither improved upon the functioning of a computer nor went beyond well-understood, routine, and conventional activities in the field.  Chargepoint, Inc. v. Semaconnect, Inc., No. MJG-17-3717, 2018 WL 1471685 (D. Md. Mar. 23, 2018).