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The claims at issue were directed to a method and system for taking, transmitting, and organizing digital images by assigning classification information to the images taken using a mobile device and storing the images on a server while “taking into consideration the classification information.”  The district court held that the claims were invalid for failing to claim to patent eligible subject matter under Section 101.  The Federal Circuit affirmed. 

The court first considered whether the claims are directed to an “abstract idea,” in light of the Enfish requirement to consider whether the claims are directed to an improvement to computer functionality versus being directed to an abstract idea.  The court found that the claims in this case were not directed to an improvement in computer functionality but rather “are directed to the use of conventional or generic technology in a nascent but well-known environment.”  By his own words, the inventor merely sought to “provid[e] for recording, administration and archiving of digital images simply, fast and in such way that the information therefore may be easily tracked.”  Further, the specification describes no new technology and the technology that is described is done so in purely functional terms or as performing generic computer functions.  Thus, the claims are directed to the abstract idea of classifying and storing digital images in an organized manner. 

The court then considered whether the claims recite an “inventive concept” and found that they do not.  The claims’ recitation of a telephone unit, a server, an image analysis unit, and a control unit fail to add an inventive concept and their functions are well-understood, routine activities previously known to the industry and therefore behave exactly as expected according to their ordinary use.

In re TLI Communications LLC Patent Litigation, Case Nos. 2015-1372, -1376, -1377, -1378, -1379, -1382, -1383, -1384, -1385, -1417, -1419, -1421 (May 17, 2016); Opinion by: Hughes, joined by Dyk and Schall; Appealed From: United States District Court for the Eastern District of Virginia, Ellis, J. Read the full opinion here.

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