The US Court of Appeals for the Federal Circuit affirmed a
district court's determination that claims directed to an
"attention manager" display screen, but not limited to
any system components for producing the claimed result, were not
directed to patent eligible subject matter under 35 USC § 101.
Interval Licensing LLC v. AOL, Inc., Apple, Inc., Google LLC,
Yahoo!, Inc., Case Nos. 16-2502, -2505, -2506, -2507 (Fed.
Cir. July 20, 2018) (Chen, J) (Plager, J, concurring in part,
dissenting in part).
The district court invalidated Interval Licensing's patent
in an action brought for infringement against multiple parties. The
parties agreed that the claims at issue were directed to the
operation of an attention manager display screen but disagreed
whether the claimed attention manager was a patent-ineligible
abstract idea. Given the broad construction of the attention
manager as recited in the claims, the district court found that the
claims were directed to a system