CHARGEPOINT, INC. v. SEMACONNECT, INC.
- Mar 28 2019 |
- Category: CAFC Updates
ChargePoint appeals the decision of the District Court, which that the eight patent claims asserted by ChargePoint relating to charging stations for electric vehicles that are connected to a network were ineligible for patenting under 35 U.S.C. § 101. First, the CAFC finds that, looking at the problem identified in the patent, as well as the way the patent describes the invention, the specification suggests that the invention of the patent is nothing more than the abstract idea of communication over a network for interacting with a device, applied to the context of electric vehicle charging stations. The CAFC notes that the breadth of the claim language illustrates why any reliance on the specification in the § 101 analysis must always yield to the claim language. In short, the CAFC finds that the inventors had the good idea to add networking capabilities to existing charging stations to facilitate various business interactions. But that is where they stopped, and that is all they patented. While the eight claims on appeal vary in some respects, they are all directed to the abstract idea of communicating over a network for device interaction. With respect to step two of the analysis, the CAFC notes that in essence, the alleged “inventive concept” that solves problems identified in the field is that the charging stations are network-controlled. But network control is the abstract idea itself, and a claimed invention’s use of the ineligible concept to which it is directed cannot supply the inventive concept that renders the invention significantly more than that ineligible concept. The CAFC concludes that the claims are patent ineligible and affirms.