SUMMIT 6, LLC v. SAMSUNG ELECTRONICS CO., LTD. (Fed. Cir. 2015) (P) – An element described as “being provided” in a particular way may not require a separate method step

A claim limitation describing a previously recited element as “being provided” in a particular way may be interpreted as a characteristic of that element rather than a separate method step. Here, for example, a “pre-processing” step at a client device in accordance...

SOCIEDAD ESPANOLA v. BLUE RIDGE X-RAY COMPANY (Fed. Cir. 2015) (NP) – Ambiguous claims terms will be generally interpreted consistent with the focus of the specification

Ambiguous claims terms will be generally interpreted consistent with the focus of the specification. Here, for example, the claimed “two insulated chambers” were found to require no more than mere electrical insulation based on the patent’s overall focus on electrical...

INTELLECTUAL VENTURES I LLC v. CAPITAL ONE FINANCIAL (Fed. Cir. 2015) (P) – Key claim limitations broadly encompassing known practices show that claims are directed to an abstract idea

Key claim limitations broadly encompassing known practices may demonstrate that the claims are directed to an abstract idea for the purposes of establishing subject matter eligibility under 35 U.S.C. § 101. Here, for example, providing customized web page content to a...

INTERNET PATENTS CORPORATION v. ACTIVE NETWORK, INC. (Fed. Cir. 2015) (P) – The innovative mechanism for achieving abstract idea must be claimed and more than generic data collection

The “inventive concept” requirement for patent eligibility under 35 U.S.C. §101 requires that the innovative mechanism for achieving an otherwise abstract idea must be recited in the claims and must involve more than merely generic data collection. Here, for example,...

CEPHALON, INC. v. ABRAXIS BIOSCIENCE, LLC (Fed. Cir. 2015) (NP) – A definition need only be widely rather than universally accepted to form the basis for claim construction

A definition need only be widely accepted rather than universally accepted to form a proper basis for claim construction. Here, for example, although the patentee noted that the definition of the claimed “nanoparticles” and “microparticles” as being between 1 to 1000...