Federal Circuit finds “Device Configured to Display” Claim not Abstract
By Michael Bonella // February 6, 2018
In Core Wireless Licensing, S.A.R.L. v. LG Electronics, Inc., the Federal Circuit affirmed summary judgment that a claim for a “computing device configured to display” claimed patent eligible subject matter. Nos. 2016-2684 & 2017-1922 (Jan. 25, 1988 Fed. Cir.). The asserted patents disclosed improved display interfaces for small screens, such as mobile telephone screens. The improved interface provided a summary window that displayed a limited list of common functions and commonly accessed data, which could be reached directly from the main menu. A representative claim provided:
A computing device comprising a display screen,
the computing device being configured to display on the screen a menu listing one or more applications, and
additionally being configured to display on the screen an application summary that can be reached directly from the menu,
wherein the application summary displays a limited list of data offered within the one or more applications,
each of the data in the list being selectable to launch the respective application and enable the selected data to be seen within the respective application, and
wherein the application summary is displayed while the one or more applications are in an un-launched state.
The Federal Circuit held that the claims were not directed to an abstract idea and did not reach the second prong of the Alice patent-eligibility test. In holding that the claims were not directed to an abstract idea, the Federal Circuit held that the claims “were directed to an improved user interface for computing devices, not to the abstract idea of an index,” as asserted by LG.
In analyzing the abstract idea issue, the Federal Circuit rejected the notion that the claims were directed to a generic idea of summarizing information because the claims were directed to “a particular manner of summarizing and presenting information in electronic devices.” The Federal Circuit reasoned that the claims had three limitations that disclosed “a specific manner of displaying a limited set of information to a user” because:
- the limitation “an application summary that can be reached directly from the menu” recited a particular manner;
- the limitation providing “each of the data in the list being selectable to launch the respective application and enable the selected data to be seen within the respective application” restrained “the type of data that can be displayed in the summary window;” and
- the limitation requiring the summary window to be “displayed while the one or more applications are in an un-launched state” requires the device applications be in a particular state.
Based on the patent specification, the Federal Circuit held that the claims disclosed an improved user interface for electronic devices. The patent specification taught that prior art interfaces were deficient because the user had to “scroll around and switch views to find the right data/functionality.” This was particularly true for small screen devices that have many layers. The Federal Circuit further explained that the invention improved efficiency by permitting a limited function/data list in a summary window without actually opening the application.
The Federal Circuit’s holding builds on the Enfish line of cases in which the Federal Circuit has found claims directed to patent-eligible subject matter. Here, the claim’s recited positive structure was a “computing device” and a “display screen,” yet the Federal Circuit found that the claim was not abstract. The Federal Circuit put much emphasis on the fact that the claim recited a particular manner and provided an improvement over the art. Patent owners should consider this recent holding in addressing patent-eligibility arguments in Federal Court or at the USPTO.