UNIVERSITY OF FLORIDA RESEARCH v. GENERAL ELECTRIC COMPANY
- Feb 26 2019 |
- Category: CAFC Updates
The University of Florida Research Foundation, Inc. (“UFRF”) is the assignee of U.S. Patent No. 7,062,251, titled “Managing Critical Care Physiologic Data Using Data Synthesis Technology.” In 2017, UFRF sued General Electric Company (“GE”) alleging infringement of the ’251 patent. GE moved to dismiss, arguing the claims of the ’251 patent are directed to ineligible subject matter under 35 U.S.C. § 101. The district court granted GE’s motion. Applying the two-step framework set forth in Alice Corp Party Ltd. v. CLS Bank International, the district court determined the claims of the ’251 patent are directed to an abstract idea and do not recite an inventive concept. UFRF appealed. Initially, the CAFC concludes that UFRF, by bringing its claim of infringement, waived its sovereign immunity not only as to the cause of action but also as to any relevant defenses, such as GE’s § 101 eligibility challenge. Because the ’251 patent claims recite the abstract idea of “collecting, analyzing, manipulating, and displaying data,” and the ’251 patent proposes using “a general-purpose computer” to carry it out, the CAFC finds that the claims do no more than simply instruct the practitioner to implement the abstract idea on a generic computer. Accordingly, the CAFC holds that the claims are not patent eligible under § 101 and affirms.