The Federal Circuit has affirmed a district court decision finding that a patent for a transmission signal decoding method was patent ineligible under 35 U.S.C. § 101.
Technology in Ariscale, LLC appealed the judgment of the United States District Court for the Central District of California determining that claims 1 and 14 of its US Patent No. 8,139,652 were invalid.
The Federal circuit noted that
Claim 1 is representative of claim 14 … and recites:
- A computer-implemented method for decoding a transmission signal, the method comprising:
receiving, using a computer processor, the transmission signal, which is formed by repeating symbols including downlink frame prefix information, encoding repeated symbols to form encoding blocks, and interleaving the encoding blocks;
deinterleaving, using a computer processor, the received transmission signal;
combining, using a computer processor, symbols at the same positions of deinterleaved encoding blocks among the repeated symbols in the deinterleaved transmission signal; and
decoding, using a computer processor, the combined symbols.
The court explained that
To determine whether a patent claim is invalid under 35 U.S.C. § 101, we apply the two-step framework set forth by the Supreme Court in Mayo Collaborative Servs. v. Prometheus Lab’ys, Inc., 566 U.S. 66, 77–80 (2012) and Alice Corp. Pty. Ltd. v. CLS Bank Int’l, 573 U.S. 208, 217 (2014). At step one, we determine whether the claim at issue is “directed to” a patent-ineligible concept. … At step two, we “consider the elements of each claim both individually and ‘as an ordered combination’ to determine whether the additional elements ‘transform the nature of the claim’ into a patent-eligible application.” … The Supreme Court has described the step two analysis “as a search for an ‘inventive concept.’”
Ariscale argued that the district court erred by characterizing claim 1 of the ’652 patent as being “directed to receiving, manipulating, and decoding data.”
The Federal Circuit disagreed, saying that
The district court’s characterization accurately reflects that claim 1 covers “[a] computer-implemented method for decoding a transmission signal” that comprises steps including “receiving,” “deinterleaving,” “combining,” and “decoding” the information in the transmission signal.
The Federal Circuit also agreed with the district court that claim 1 is directed to the abstract idea of “receiving, manipulating, and decoding data.”
The court previously held that such functions fall within the realm of abstract ideas. For example, in the 2023 case of Hawk Tech. Sys., LLC v. Castle Retail, LLC, the court held that “[E]ncoding and decoding image data and converting formats, including when data is received from one medium and sent along through another, are by themselves abstract ideas.”
Ariscale argued that claim 1 was “directed to an improvement in wireless communication technology,” and specifically to “improving reception performance for repeatedly transmitted [DFP] information,” such as providing improved bit error rates and signal-to-noise ratios.
However, said the Federal Circuit,
The advantage disclosed by the specification is linked to implementation of a separate scheme, involving combining and decoding, for the DFP information as compared to the rest of the signal. … But claim 1 does not cover separate reception schemes for the DFP information as compared to other portions of the transmission signal and instead discloses that all recited functions of claim 1 are performed on a “transmission signal, which is formed by repeating symbols including [DFP] information.” … (emphasis added). The reception performance benefits described in the specification are therefore not tied to the claims at issue.
Noted the court, “[F]eatures that are not claimed are irrelevant as to step 1 or step 2 of the [Alice/Mayo] analysis.”
Ariscale also argued that claim 1 of the ’652 patent recites an inventive concept in the ordered combination of steps claimed.
Specifically, Ariscale argued that the claimed order of implementing the “combining” step after “deinterleaving,” but before “decoding,” made the claimed method a patent-eligible ordered combination.
The court disagreed, finding that “all claimed steps aside from the “combining” step were used in prior art decoding methods.”
Also, said the court, “the specification indicates that this “combining” step involves basic arithmetic which can be performed mentally or by hand or other conventional methods.”
Thus, the Federal Circuit affirmed the district court’s judgment that claims 1 and 14 of the ’652 patent are invalid under §101.
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