ANCORA TECHNOLOGIES, INC. V. HTC AMERICA, INC.
- Nov 16 2018 |
- Category: CAFC Updates
Ancora Technologies, Inc.’s U.S. Patent 6,411,941 is entitled “Method of Restricting Software Operation Within a License Limitation” and relates to methods of limiting a computer’s running of software not authorized for that computer to run. Ancora sued HTC America alleging infringement of the ’941 patent and HTC moved to dismiss on the ground that the patent’s claims are invalid because their subject matter is ineligible for patenting under 35 U.S.C § 101. The district court granted HTC’s motion to dismiss, concluding that the claims are directed to, and ultimately claim no more than, an abstract idea. The CAFC, however, concludes that the claims are not directed to ineligible subject matter. Rather, the CAFC holds, the claimed advance is a concrete assignment of specified functions among a computer’s components to improve computer security, and this claimed improvement in computer functionality is eligible for patenting. As a result, the claims are not invalid under § 101 and the CAFC reverses and remands.