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Uniloc USA, Inc. v. LG Electronics USA, Inc. (Fed. Cir. Apr. 20, 2020)

The Court of Appeals for the Federal Circuit held that the claims of U.S. Pat. No. 6,993,049 are not directed to patent ineligible subject matter and thus reversed and remanded the district court's decision.

The Federal Circuit stated that "[w]e have routinely held software claims patent eligible under Alice step one when they are directed to improvements to the functionality of a computer or network platform itself" and held that "the claims at issue are directed to a patent-eligible improvement to computer functionality, namely the reduction of latency experienced by parked secondary stations in communication systems." Regarding the claim language of “adding to each inquiry message prior to transmission an additional data field for polling at least one secondary station," the Federal Circuit explained that "this change in the manner of transmitting data results in reduced response time by peripheral devices which are part of the claimed system."

Regarding LG's contention that the claims themselves must expressly mention the reduced latency achieved by the claimed system, the Federal Circuit also explained that "[the claims] need not articulate the advantages of the claimed combinations to be eligible."

Read the case here.

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