On Feb. 26, 2019, the Federal Circuit affirmed the district court's motion to dismiss for failure to state a claim because the asserted claims were invalid under Section 101. Univ. of Fla. Research v. General Elec. Co., 2018-1284 (Fed. Cir. Feb. 26, 2019). University of Florida, the owner of US 7,062,251 directed to managing critical care physiologic data using data synthesis technology, sued General Electric for infringement. GE filed a Rule 12(b)(6) motion to dismiss arguing that the patent claims are directed to ineligible subject matter. The N.D. Fla. court granted the motion and applying the Alice test determined the claims to be directed to an abstract idea and lacking an inventive concept. Univ. of Florida appealed arguing that sovereign immunity precludes a Section 101 challenge.
In affirming the district court's decision, the Federal Circuit held that (a) the district court had subject matter jurisdiction because the plaintiff waived its sovereign immunity by bringing an infringement action and Section 101 eligibility challenge is a defense to infringement, and (b) the patent claims are directed to abstract idea of "collecting, analyzing, manipulating, and displaying data".
Full text of the opinion is available here.
In affirming the district court's decision, the Federal Circuit held that (a) the district court had subject matter jurisdiction because the plaintiff waived its sovereign immunity by bringing an infringement action and Section 101 eligibility challenge is a defense to infringement, and (b) the patent claims are directed to abstract idea of "collecting, analyzing, manipulating, and displaying data".
Full text of the opinion is available here.
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