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Chamberlain Group, Inc. v. Linear LLC

Representative Claim

  1. (‘977 patent) An apparatus comprising:

a movable barrier operator including a controller for controlling movement of a moveable barrier; and

a network interface electronically connected to the controller for connecting the controller to a network;

wherein the network interface responds to requests received on the network by sending a status of the movable barrier over the network and;

wherein the network interface receives a status change request from the network and the controller responds to the status change request by moving the barrier..

  1. (‘977 patent) A method for checking the status of a movable barrier comprising the steps of:

receiving from a network client over a network, a status request for a movable barrier;

determining a status of the movable barrier;

sending a status of the movable barrier over the network to the network client in response to the status request and;

wherein the movable barrier comprises a barrier movement operator for controlling the movement of the barrier and the method comprises receiving a status change request from the network client and controlling movement of the barrier in response to the status change request.

Posture:

12(b)(6) Motion to Dismiss for patent ineligibility under 35 USC 101.

Abstract Idea: No

The ‘977 Patent claims do not fall within the contours of an abstract idea or patent-ineligible computer implementation of an abstract idea as they have physical and tangible components that are directed to more than performance of an abstract idea. See DDR Holdings, 773 F.3d at 1256.

The ‘977 Patent claims are not directed to apparatus and methods that are capable of being “performed mentally” nor are they the “equivalent of human mental work.” See CyberSource Corp. v. Retail Decisions, Inc., 654 F.3d 1366, 1373 (Fed. Cir. 2011) (explaining that a “method that can be performed by human thought alone” is an abstract idea). In short, the ‘977 Patent claims are directed to opening and closing a movable barrier (e.g., garage door) using a computer network for communication between the monitor or operator (including a controller), and movable barrier.

The Alarm System Patents are directed to monitoring the status of a movable barrier in such a way that a change in that status can set off an alarm or adjust the timing of an alarm disarmament or actuation. The claims of the Alarm System Patents—like those of the ‘977 Patent—include a limitation to a movable barrier operator that is configured to control movement of a movable barrier. . . . Accordingly, the Alarm System Patents—directed to integrating an alarm system and a movable barrier to include communication between the two—do not claim an abstract idea and are patent-eligible subject matter. The analysis under Alice, therefore, ends.

Something More: Yes

Although the ‘977 Patent claims are not directed to an abstract idea, as explained above, even if the Court found the concept of opening and closing a door to be an abstract idea—as Defendant asserts—the ‘977 Patent claims would still clear the hurdle of § 101 patent eligibility because the claims include an inventive concept. . . . Defendant ignores the garage door opener and controller, as well as ignoring the requirement for the network interface of the ‘977 Patent claims to be one that must connect the garage door opener to the network—a particular type of interface. The additional elements included in the ‘977 Patent claims provide an inventive concept beyond opening and closing a door.

Furthermore, this implementation of the idea of opening and closing a door—limited to the additional use of a movable barrier operator and a controller—does not preempt every technique for opening and closing a door. In particular, the claimed implementation is limited to a system that can identify the status of the door and change that status over a network.