In Re TLI Communications LLC Patent Litigation

In Re TLI Communications LLC Patent Litigation, Lead Appeal No. 2015-1372, --- F.3d --- (Dyk, Schall, and Hughes, Circuit Judge) (May 17, 2016)

Patent(s):    

6,038,295 | Entitled, “Apparatus and method for recording, communicating and administering digital images” 

Disposition:               

Affirmance of Motion to Dismiss for Failure to State a Claim due to Patent Ineligibility under § 101.

Abstract Idea:

Yes

Something More:

No

Technology:              

Method and system for taking, transmitting, and organizing digital images. 

Summary:                 

The Federal Circuit affirmed the district court’s ruling that the patent claimed no more than the abstract idea of classifying and storing digital images in an organized manner. The district court noted that “at the time of the invention, it was known how to ‘digitize, compress and transmit individual still pictures, such as photographs.’” The district court declined to give patentable weight to the claims’ recitation of a telephone unit or a server, or to the “means for allocating” limitation in claims 1 and 25.  

The Federal Circuit held that “we find that, like the claims at issue in Content Extraction which were directed to “collecting data,” “recognizing certain data within the collected data set,” and “storing the recognized data in memory.” The court noted that attaching classification data, such as dates and times, to images for the purpose of storing those images in an organized manner is a well-established “basic concept” sufficient to fall under Alice step 1.” 

Addressing patentee’s arguments that there was sufficient structure described in dependent claims to overcome the finding of an abstract idea, the Federal Circuit found that while claim 17 recited concrete, tangible components such as “a telephone unit” and a “server,” “the specification does not describe a new telephone, a new server, or a new physical combination of the two. The specification fails to provide any technical details for the tangible components, but instead predominately describes the system and methods in purely functional terms.