Electric Power Group, LLC v. Alstom S.A., Alstom Grid, Inc., Psymetrix, Ltd., Alstom Limited

Electric Power Group, LLC v. Alstom S.A., Alstom Grid, Inc., Psymetrix, Ltd., Alstom Limited., No. 2015-1778 (Fed. Cir. Aug. 1, 2016) 

Patent(s):

  • 7,233,843 | Entitled “Real-time performance monitoring and management system” 
  • 8,060,259 | Entitled “Wide-area, real-time monitoring and visualization system”
  • 8,401,710 | Entitled “Wide-area, real-time monitoring and visualization system”

Disposition:               

Affirm of grant of summary judgment of invalidity.

Abstract Idea:

Yes

Something More:

No

Technology:              

Real-time performance monitoring system for monitoring an electric power grid.

Summary:                 

The Federal Circuit agreed with the district court that the claims were directed to abstract matter, citing precedent finding that collecting information is an abstract idea, even when limited to specific content. The court distinguished the claims here from those found not invalid in Enfish, as those claims were directed to “improvement in computers as tools”, but the instant claims only used computers as tools. Turning to the second step of Alice, the Federal Circuit found no inventive concept. The claims did not even require new source of type of information, or new techniques for analyzing it, which potentially could have added inventive material.