KONINKLIJKE KPN N.V. v. GEMALTO M2M GMBH
- Nov 15 2019 |
- Category: CAFC Updates
Koninklijke KPN owns U.S. Patent No. 6,212,662 (relating to methods of generating “check data” that varies the way check data is generated from time to time so that the same defective check data does not continue to be produced for the same type of persistent systematic error in data transmission systems) and sued Gemalto for infringement. Gemalto moved for judgment on the pleadings alleging that all the claims of the ’662 patent were ineligible under 35 U.S.C. § 101. The district court granted Gemalto’s motion, concluding that the claims recite no more than mere abstract data manipulation operations, such as “reordering data and generating additional data.” In performing the first step of an Alice analysis, the CAFC concludes that rather than being merely directed to the abstract idea of data manipulation, the claims are directed to an improved check data generating device that enables a data transmission error detection system to detect a specific type of error that prior art systems could not. Accordingly, the CAFC reverses.