Koninklijke KPN N.V. v. Gemalto M2M GmbH
United States Court of Appeals for the Federal Circuit
November 15, 2019, Decided
2018-1863, 2018-1864, 2018-1865
[*1145] Chen, Circuit Judge.
Plaintiff-Appellant Koninklijke KPN N.V. (KPN) owns U.S. Patent No. 6,212,662 ('662 patent). KPN sued Gemalto M2M GmbH, Gemalto Inc., Gemalto IOT LLC, TCL Communication Technology Holdings Limited, TCL Communication, Inc., TCT Mobile, Inc., TCT Mobile (US) Inc., TCT Mobile (US) Holdings, Inc., and Telit Wireless Solutions, Inc. (collectively "Appellees") for infringement of the '662 patent in the United States District Court for the District of Delaware. Appellees moved for judgment on the pleadings under Federal Rule of Civil Procedure 12(c) alleging that all four claims (claims 1-4) of the '662 patent were ineligible under 35 U.S.C. § 101. The district court granted Appellees' motion with respect to all four claims, concluding that the claims recite no more than mere abstract data manipulation operations, such as "reordering data and generating additional data." J.A. 23. On appeal, KPN only challenges the district court's ineligibility decision with respect to dependent claims 2-4. As to these appealed claims, we reverse. Rather than being merely directed to the abstract idea of data manipulation, these claims [**3] are directed to an improved check data generating device that enables a data transmission error detection system to detect a specific type of error that prior art systems could not.
In data transmission systems, it is common to generate something called "check data" to check whether data was accurately transmitted over a communications channel. Check data is generated based on the original data and thus serves as a shorthand representation of a particular block of data. By comparing the check data generated at both ends of the communication channel, error detection systems may be able to infer whether errors occurred during transmission. For example, if the check data from both ends match, the system infers that the content of the received data block is the same as what was transmitted and thus concludes that no errors occurred during transport.
But, as the '662 patent recognizes, matching check data is not always a reliable indicator of accurate data transmissions. According to the patent, certain generating functions coincidentally produce the same check data for a corrupted data block and an uncorrupted data block. When this happens, the check data is functionally defective, because the system [**4] will mistakenly believe that there were no errors in the data transmission. The problem of defective check data is aggravated for a particular type of persistent error, i.e., "systematic error," that repeats across data blocks in the same way. According to the '662 patent, prior art error detection systems were unable to reliably detect systematic errors. Once the prior art system generated defective check data for an initial data block with a given systematic error, the system would continue to generate defective check data for subsequent data blocks with the same systematic error, thus allowing these types of errors to persist in the system.Read The Full CaseNot a Lexis Advance subscriber? Try it out for free.
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942 F.3d 1143 *; 2019 U.S. App. LEXIS 34075 **; 2019 U.S.P.Q.2D (BNA) 439585; 2019 WL 6041479
KONINKLIJKE KPN N.V., Plaintiff-Appellant v. GEMALTO M2M GMBH, GEMALTO INC., GEMALTO IOT LLC, TCL COMMUNICATION TECHNOLOGY HOLDINGS LIMITED, TCL COMMUNICATION, INC., TCT MOBILE (US) HOLDINGS, INC., TCT MOBILE (US) INC., TCT MOBILE, INC., TELIT WIRELESS SOLUTIONS, INC., Defendants-Appellees LG ELECTRONICS, INC., Intervenor
Prior History: [**1] Appeals from the United States District Court for the District of Delaware in Nos. 1:17-cv-00086-LPS, 1:17-cv-00091-LPS, 1:17-cv-00092-LPS, Chief Judge Leonard P. Stark.
3G Licensing, S.A. v. Blackberry Ltd., 302 F. Supp. 3d 640, 2018 U.S. Dist. LEXIS 46843 (D. Del., Mar. 22, 2018)
generating, permutation, blocks, systematic, varying, recite, technological, abstract idea, ineligible, prior art, transmission, detection, patent-eligible, improved, functionality, bit, modified, capture, patent, district court, invention, non-abstract, configured, persistent, detection system, specification, inventors, data transmission, reordering, pleadings
Civil Procedure, Appeals, Standards of Review, De Novo Review, Judgments, Pretrial Judgments, Judgment on Pleadings, Patent Law, Jurisdiction & Review, Subject Matter