• Jun 25 2019
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  • Category: CAFC Updates

Cellspin sued Fitbit and others for infringing various claims of four different patents relating to connecting a data capture device, e.g., a digital camera, to a mobile device so that a user can automatically publish content from the data capture device to a website. Fitbit moved to dismiss, arguing that the patents are ineligible for patent protection under 35 U.S.C. § 101 and the district court granted these motions and awarded attorney fees to Fitbit. Applying the two-step test of the Alice/Mayo framework, the CAFC agrees with the district court that the asserted claims are directed to an abstract idea, but finds that the district court erred with respect to the inventive concept inquiry, by ignoring allegations that, when properly accepted as true, preclude the grant of a motion to dismiss. The CAFC therefore vacates the district court’s dismissal and the award of attorney fees, and remands for further proceedings.

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