The Court of Appeals for the Federal Circuit ruled on 19 April that West View Research, a patent licensing company, failed to demonstrate that the patents had sufficient inventive concept to pass the Supreme Court’s Alice Corp v CLS Bank test.
West View Research asserted the seven patents, which purport to cover various aspects of an in-car hands-free phone system, including hardware, software and connective capabilities to peripheral devices, against Audi, Volkswagen, Hyundai, Nissan and Tesla in the US District Court for the Southern District of California.
The Federal Circuit affirmed the district court’s ruling, holding that all of the patents were directed toward abstract ideas and lacked the inventive concept required to transform them into patentable subject matter.
“Whether analysed individually or as an ordered combination, the claims recite conventional elements at a high level of generality and do not constitute an inventive concept,” the Federal Circuit explained.
“These claims do not go beyond receiving or collecting data queries, analysing the data query, retrieving and processing the information constituting a response to the initial data query, and generating a visual or audio response to the initial data query.”
West View Research’s patents failed the Supreme Court’s two-part test as laid down in Alice Corp v CLS Bank, which requires claims directed toward an abstract idea to demonstrate inventive concept and the transformation into patentable subject matter.