CALL US: 206.533.3854
CALL US  206.533.3854
AEON Law logo full color transparent
By LG전자 - LG전자, 깜빡임 없는 55인치 3D OLED TV 공개, CC BY 2.0,

Federal Circuit Revives Uniloc’s “Abstract” Patent

Claims aren’t too abstract
If patent solves a problem,
Says Federal Court

The Federal Circuit has revived a patent infringement case by Uniloc against LG Electronics, finding that the patent at issue wasn’t too “abstract” to be patent-eligible.

Claim 2 of the patent recites:

A primary station for use in a communications system comprising at least one secondary station, wherein means are provided

for broadcasting a series of inquiry messages, each in the form of a plurality of predetermined data fields arranged according to a first communications protocol, and

for adding to each inquiry message prior to transmission an additional data field for polling at least one secondary station.

The district court had held that the claims were patent-ineligible as “directed to the abstract idea of ‘additional polling in a wireless communication system,’” without a saving inventive concept.

But the Federal Circuit disagreed, finding that

the claimed invention changes the normal operation of the communication system itself to “overcome a problem specifically arising in the realm of computer networks.” In doing so, the claimed invention, like the improvement in computer memory we held patent eligible in Visual Memory, enables the communication system to accommodate additional devices, such as battery-operated secondary stations, without compromising performance.

Importantly, the claims were tied to a specific technical benefit – reducing latency.

As the court noted,

Our precedent is clear that software can make patent-eligible improvements to computer technology, and related claims are eligible as long as they are directed to non-abstract improvements to the functionality of a computer or network platform itself.

The case is Uniloc USA, Inc. v. LG Electronics USA, Inc.

Just like the haiku above, we like to keep our posts short and sweet. Hopefully, you found this bite-sized information helpful. If you would like more information, please do not hesitate to contact us here.

Related Articles

Just Because It’s on the Internet Doesn’t Mean It’s “Publicly Accessible”

The Patent Trial and Appeal Board (PTAB or Board) has denied institution of a petition for inter partes review (IPR) because the petitioner failed to ...
Read More

Trademark Denied for “ChatGPT”

The US Patent and Trademark Office (USPTO) has denied OpenAI’s applications to trademark “ChatGPT” and “GPT.” The Final Office Action states, “Registration is refused because the applied-for mark ...
Read More

Federal Circuit: “Improving User Experience” Isn’t Patentable

The Federal Circuit has affirmed a lower court decision that patent claims for methods and systems for improving how search results are displayed to users ...
Read More

Stay Informed

Sign up to receive Patent Poetry—a monthly roundup of key IP issues in our signature haiku format. Four articles (only 68 syllables); zero hassle.



Artificial Intelligence

Blockchain & Cryptocurrency

Computer Technology & Software

Consumer Electronics

Electrical Devices



Mechanical Devices

Consumer & Retail Products

Hardware & Tools

Toys & Games



Chemical Compounds

Digital Health

Healthcare Products



Books & Publications

Brand Creation

Luxury Products

Photography & Video

Product Design