Zimmers et al v. Eaton Corporation et al.

Zimmers et al v. Eaton Corporation et al., No. 2-15-cv-02398 (Marbley, D.J.) (S.D. Ohio Aug. 2, 2016)


  • 9,015,256 | Entitled “Alert notification systems”
  • RE44,535 | Entitled “Alert notification systems”


Grant of Defendant’s Motion for Judgment on the Pleadings for ineligible subject matter under § 101.

Abstract Idea:


Something More:



Providing emergency notification to multiple persons and/or geographic regions.


The court considered only those claims the Plaintiffs explicitly discussed in their opposition to Defendants’ selection of a representative claim. The court concluded the claims are directed to the abstract idea of providing alert notifications to multiple persons, a common business activity before the issuance of the patents. The court rejected arguments of the role of types of alerts and delivery mechanisms as novelty arguments. The claims lacked an inventive concept as they only used routine and conventional functions of existing technology. The claims did not provide a solution for a problem created by new technology but conceded that the claims implemented features that used existing standards and technology.