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Burnett v. Panasonic, et al.

Representative Claim

1. A geospatial media recorder, comprising:

converting means for converting longitude and latitude geographic degree, minutes, and seconds

(DMS) coordinate alphanumeric representations or decimal equivalent geographic coordinate alphanumeric representations and altitude alphanumeric representations into individual discrete all-natural number geographic coordinate and measurement representations; and

combining means for concatenating the individual discrete all-natural number geographic

coordinate and measurement representations into a single discrete all-natural number geospatial coordinate measurement representation for identification of a geospatial positional location at, below, or above earth’s surface allowing user to geospatially reference entities or objects based on the identified geospatial positional location and point identification.

Posture:

Appeal from the United States District Court for the District of Maryland in No. 8:17-cv-00236-PX.

Abstract Idea: Yes

The Federal Circuit agreed with the District Court at Step 1 that the claims constitute an abstract idea because they employ a mathematical methodology “for converting geographic coordinates into alphanumeric representations.” In explanation, the opinion states:

“Both claims 1 and 9 are directed to, first, converting longitude and latitude coordinates into natural numbers—i.e. removing the decimal points and replacing any ‘+’ signs with a ‘1’ and any ‘-’ signs with a 0—and second, concatenating the resulting natural numbers—i.e. joining the strings of resulting numbers together. See, e.g., ‘286 patent, at col. 12, l. 50-col. 13, l. 14; id. at Figure 26. In sum, the claims apply a mathematical methodology to convert geospatial coordinates into a single string of natural numbers.”

Something More: No

The Federal Circuit also agreed with the District Court’s Step Two determination “that the additional features, viewed individually and as an ordered combination, are not ‘sufficient to transform the nature of the claim[s]’” into patentable subject matter. Mayo Collaborative Servs. v. Prometheus Labs, Inc., (2012) 566 U.S. 66, 67. In summary, the opinion states:

“[C]laim 9 does no more than instruct a user to implement the abstract idea of converting geospatial coordinates into natural numbers, and claim 1 merely provides for a ‘Geospatial Media Recorder’ to implement the same abstract idea. Thus, these purportedly new combinations do not transform the abstract idea into a patent-eligible concept under our precedent.”