Federal Circuit Upholds Md. District Court's Section 101 Ruling

Tuesday, April 30, 2019

In Chargepoint, Inc. v. Semaconnect, Inc., the Federal Circuit affirmed the ruling of Senior Judge Marvin J. Garbis of the U.S. District Court for the District of Maryland that four patents directed to charging stations for electric vehicles were ineligible for patenting under 35 U.S.C. § 101.  The patents involved the creation of networked electric vehicle charging stations.  The Federal Circuit lauded the inventors as having “the good idea to add networking capability to existing charging stations to facilitate various business interactions.”  Nonetheless, the Federal Circuit found the idea of networked charging stations was abstract under Supreme Court case law, and that the patent claims failed to recite an inventive concept that rendered the claims “significantly more” than the abstract idea.  Specifically, the Federal Circuit opined that the patent gave no indication that the claimed invention involved adding network connectivity to charging stations in a way that was not well-understood, routine, and conventional.  The Federal Circuit held that the patent claims in Chargepoint to be ineligible for patent protection and invalidated the claims.  Chargepoint, Inc. v. Semaconnect, Inc., 2018-1739, --- F.3d --- (Fed. Cir. Mar. 28, 2019).