IOENGINE, LLC v INGENICO INC., FEDERAL CIRCUIT 2024
IOENGINE, LLC appealed decisions of the U.S. Patent and Trademark Office Office’s Patent Trial and Appeals Board that found unpatentable certain claims of U.S. Patent Nos. 8,539,047; 9,059,969; and 9,774,703.
The patents relate to a tunneling client access point (TCAP) that is a “highly secure, portable, power efficient storage and data processing device” that, upon plugging in to an access terminal (desktop or laptop computer), may make use of the terminal’s traditional user interface and input/output peripherals while the TCAP provides storage, execution, and/or processing resources. The TCAP tunnels data through the access terminal by allowing data to be provided through the access terminal’s input/output facilities for the user to observe without the data actually residing on the access terminal.
Claim 1 of the ‘969 patent is representative and…
USC brought suit for infringement against Facebook, Inc. (now Meta Platforms, Inc.), asserting that its “News Feed” feature infringes claims 1–17 of U.S. Patent No. 8,645,300. The software patent relates to a search engine software method for predicting which webpages to recommend to a web visitor based on inferences of the visitor’s “intent.” The software patent states that website navigation can be enhanced “by recording a visitor’s intent and recording page rankings that indicate how well the pages of a website match the visitor’s intent.” The software patent further explains that visitor intent can be inferred from historical intent data, the Uniform Resource Locator, the user’s visits, and optional user intent confirmation. The lower court, the Western District…
Trinity Info Media, LLC sued Covalent, Inc. for infringement of U.S. Patent Nos. 9,087,321 and 10,936,685 relating to methods and systems for connecting users based on their answers to polling questions. U.S. Patent No. 9,087,321 teaches that its claimed invention is “directed to a poll-based networking system that connects users based on similarities as determined through poll answering and provides real-time results to the users. The claimed invention of the ’685 patent is “directed to a poll-based networking and ecommerce system that connects users to other users, or products, goods and/or services based on similarities as determined through poll answering and provides real-time results to the users.
A multi-format digital video product system capable of maintaining full-bandwidth resolution while providing professional quality editing and manipulation of images, which is capable of conserving bandwidth while preserving data is not patent-eligible.
The ITC took 35 U.S.C. 
Though creating digital location histories is not patent eligible, a method of enhancing digital search results may be patent eligible.
Functionally recited claims to organizing and displaying visual information are not patent-eligible.
At the pleadings stage, all that is required to survive a motion to dismiss based on Alice are plausible allegations in a complaint that the claims are patent-eligible.
Mr. Smith’s argued that the first step in analyzing a claim must be to determine whether the claim is useful. And if it is useful, it is by law patent-eligible. The Federal Circuit disagreed.