A Digital Camera (A Mechanical/Electronic Device) Is Patent Ineligible

Yu sued Apple for infringement of the claims of U.S. Patent 6,611,289. The district court granted Defendants' motion to dismiss on the basis that the asserted claims were invalid under 35 U.S.C. § 101. Yu appealed. The Federal Circuit ("the Court") found no error and affirmed.

The '289 patent is titled "Digital Cameras Using Multiple Sensors with Multiple Lenses." The district court granted Defendants' Rule 12(b)(6) motion to dismiss with prejudice after concluding that each asserted claim was patent ineligible under § 101. The district court held that the asserted claims were directed to "the abstract idea of taking two pictures and using those pictures to enhance each other in some way." The district court explained that photographers have been using multiple pictures to enhance each other for a long time. The court noted that the asserted claims lack an inventive concept because of "the complete absence of any facts showing that the[] [claimed] elements were not