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TLI Communications v. AV Auto

Representative Claim

  1. A method for recording and administering digital images, comprising the steps of:

recording images using a digital pick up unit in a telephone unit, storing the images recorded by the digital pick up unit in a digital form as digital images,

transmitting data including at least the digital images and classification information to a server, wherein said classification information is prescribable by a user of the telephone unit for allocation to the digital images,

receiving the data by the server,

extracting classification information which characterizes the digital images from the received data, and storing the digital images in the server, said step of storing taking into consideration the classification information.

Posture:

Appeals from the United States District Court for the Eastern District of Virginia in Nos. 1:14-md-02534-TSEJFA, 1:14-cv-00136-TSE-JFA, 1:14-cv-00137-TSE-JFA, 1:14-cv-00138-TSE-JFA, 1:14-cv-00139-TSE-JFA, 1:14-cv-00140-TSE-JFA, 1:14-cv-00142-TSE-JFA, 1:14-cv-00785-TSE-JFA, 1:14-cv-00788-TSE-JFA, 1:14-cv-00790-TSEJFA, 1:14-cv-00791-TSE-JFA, 1:14-cv-00842-TSE-JFA

Abstract Idea: Yes

The Federal Circuit agreed with the District Court that the claims constitute an abstract idea because they are “drawn to the concept of classifying an image and storing the image based on its classification,” and because they fail to improve computer functionality.  The Court explained:

“The claims here are not directed to a specific improvement to computer functionality. Rather, they are directed to the use of conventional or generic technology in a nascent but well-known environment, without any claim that the invention reflects an inventive solution to any problem presented by combining the two.”

Something More: No

The Federal Circuit also agreed with the District Court’s Step Two determination “that the claims’ recitation of a ‘telephone unit,’ a ‘server,’ an ‘image analysis unit,’ and a ‘control unit’ fail to add an inventive concept sufficient to bring the abstract idea into the realm of patentability. In summary, the Court concluded that:

“[a]lthough the claims recite that the abstract idea of classifying and storing digital images in an organized manner is carried out in a telephone system, the ‘295 patent fails to provide the requisite details necessary to carry out that idea. Just as ‘[s]teps that do nothing more than spell out what it means to ‘apply it on a computer’ cannot confer patent eligibility,’ Intellectual Ventures I, 792 F.3d at 1371-72 (citing Alice, 134 S. Ct. at 2359), here, steps that generically spell out what it means to ‘apply it on a telephone network’ also cannot confer patent eligibility.”