THE CHAMBERLAIN GROUP, INC. v. TECHTRONIC INDUSTRIES CO. LTD
- Aug 21 2019 |
- Category: CAFC Updates
Techtronic appeals from the opinion and order of the district court denying its motion for judgment as a matter of law (JMOL) that the asserted claims of Chamberlain’s U.S. Patent No. 7,224,275 (relating to an apparatus and method for communicating information about the status of a movable barrier, for example, a garage door) are directed to patent-ineligible subject matter under § 101, and granting Chamberlain’s motions for enhanced damages and attorney fees. Techtronic also appeals the jury’s verdict with respect to infringement and validity. In performing an Alice inquiry, the CAFC first concludes that claim 1 of the ’275 patent is directed to the abstract idea of wirelessly communicating status information about a system. In the second step of the Alice inquiry, the CAFC a) notes that the specification describes each individual element of the asserted claims (including the controller, the inter-face, and the wireless data transmitter) as “well understood in the art,” b) finds that these conventional components, all recited in a generic way, are no better equipped to save the claim from abstractness than were, for example, the conventional computer used in Alice, and c) concludes that the claims are patent-ineligible. Accordingly, the CAFCreverses the district court’s JMOL decision with respect to the ’275 patent on 35 U.S.C. § 101 grounds. The CAFC affirms the jury’s verdict with respect to its finding of no anticipation of claims of Chamberlain’s U.S. Patent No. 7,635,966 (relating to a rechargeable battery backup system for a barrier movement operator), vacates the district court’s injunction and its awards of enhanced damages and attorney fees, and remands to the district court for reconsideration of enhanced damages and attorney fees with respect to only the ’966 patent.