The Federal Circuit affirmed the district court’s grant of summary judgment that Electric Power’s claims are invalid under Section 101 for being directed to patent ineligible subject matter. The claims are directed to “performing real-time performance monitoring of an electric power grid by collecting data from multiple data sources, analyzing the data, and displaying the results.”
As to the “abstract idea” prong of the patent eligibility test, the court held that the claims are directed to the combination of three abstract idea processes. First, information alone is intangible. Second, analyzing information by the steps that people go through in their minds, or mathematical algorithms, without more, is a mental process that itself is an abstract idea. Lastly, merely presenting the results of abstract processes of collecting and analyzing information, without more (such as identifying a particular tool for presentation) is abstract as an ancillary part of such collection and analysis. The court further distinguished the present claims from those in Enfish on the grounds that the claims in Enfish were directed to an improvement in computers as tools, whereas here the claims are directed to certain independently abstract ideas that use computers as tools.
As to the second “inventive concept” prong of the patent eligibility test, the court held that limiting the claims to the particular technological environment of power-grid monitoring is, without more, insufficient to transform the abstract idea to a patent-eligible inventive concept. Here, the claims are not differentiated from an ordinary mental process of selecting information for collection, analysis, and display. Further, the claims do not require a new source or type of information. Lastly, the claims do not require any nonconventional computer or other components and thus these components are insufficient to confer patentability.
Electric Power Group, LLC v. Alstom S.A., Case No. 2015-1778 (August 1, 2016); Opinion by: Taranto, joined by Bryson and Stoll; Appealed From: United States District Court for the Central District of California, Bernal, J. Read the full opinion here.