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Uniloc USA, Inc. v. LG Elecs. USA, Inc.

United States Court of Appeals for the Federal Circuit

April 30, 2020, Decided

2019-1835

Opinion

Moore, Circuit Judge.

Uniloc USA, Inc., Uniloc Luxembourg S.A. and Uniloc 2017 LLC (collectively, Uniloc) sued LG Electronics USA, Inc., LG Electronics MobileComm U.S.A., Inc. and LG Electronics, Inc. (collectively, LG) in the United States District Court for the Northern District of California, alleging infringement of claims of U.S. Patent No. 6,993,049. LG moved to dismiss Uniloc's Second Amended Complaint under Fed. R. Civ. P. 12(b)(6), arguing the claims of the '049 patent are ineligible under 35 U.S.C. § 101. The district court granted LG's motion, determining that the asserted claims are directed to an abstract idea and do not recite an inventive concept. Uniloc USA Inc. v. LG Elecs. USA Inc., 379 F. Supp. 3d 974, 1000 (N.D. Cal. 2019). Because we hold the claims are not directed to ineligible subject matter under § 101, we reverse and remand.

Background

The '049 patent is directed to a communication system [*2]  comprising a primary station (e.g., a base station) and at least one secondary station (e.g., a computer mouse or keyboard). '049 patent at Abstract; id. at 1:28-31, 3:31-34. In conventional systems, such as Bluetooth networks,1 two devices that share a common communication channel form ad hoc networks known as "piconets." Id. at 1:19-21. Joining a piconet requires the completion of two sets of procedures, namely an "inquiry" procedure and a "page" procedure. Id. at 1:54-55. The inquiry procedure allows a primary station to identify secondary stations and it allows secondary stations to issue a request to join the piconet. Id. at 1:56-57. The page procedure in turn allows a primary station to invite secondary stations to join the piconet. Id. at 1:57-58. Together, it can take several tens of seconds to complete the inquiry and page procedures so that a device joins a piconet and is able to transfer user input to the primary station. Id. at 1:58-61. Once a piconet is formed, the primary station "polls" secondary stations to determine whether they have data to share over the communication channel.

Because many secondary stations are battery-operated, secondary stations may enter a "park" mode and [*3]  cease active communications with the primary station to conserve power. Id. at 1:43-45, 1:62-66. A secondary station in parked mode remains synchronized with the primary station, but it must be polled before it can leave park mode and actively communicate with the primary station. Id. at 1:43-51. In conventional systems, primary stations alternate between sending inquiry messages to identify new secondary stations and polling secondary stations already connected to the piconet, including parked devices, to determine whether they have information to transmit. Therefore, under the conventional polling process, a secondary station could experience delays of tens of seconds both in initially joining a piconet and in transmitting data after entering park mode.

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2020 U.S. App. LEXIS 13876 *; 957 F.3d 1303; 2020 U.S.P.Q.2D (BNA) 10450

UNILOC USA, INC., UNILOC LUXEMBOURG S.A., UNILOC 2017 LLC, Plaintiffs-Appellants v. LG ELECTRONICS USA, INC., LG ELECTRONICS MOBILECOMM U.S.A., INC., LG ELECTRONICS, INC., Defendants-Appellees

Prior History:  [*1] Appeal from the United States District Court for the Northern District of California in No. 5:18-cv-06738-LHK, Judge Lucy H. Koh.

Uniloc USA Inc. v. LG Elecs. USA Inc., 379 F. Supp. 3d 974, 2019 U.S. Dist. LEXIS 60900 (N.D. Cal., Apr. 9, 2019)

Disposition: REVERSED AND REMANDED.

CORE TERMS

station, secondary, polling, eligible, patent, invention, messages, recite, functionality, communication system, conventional, piconet, district court, abstract idea, Electronics, ineligible, network, parked, patent-eligible, Technologies, join, user, software, enables, latency

Civil Procedure, Appeals, Standards of Review, De Novo Review, Defenses, Demurrers & Objections, Motions to Dismiss, Failure to State Claim, Patent Law, Subject Matter, Utility Patents, Process Patents, Computer Software & Mental Steps