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ARTICLE · 16 JULY 2026

Federal Circuit Affirms 'Without Assistance' Reading

Lerner David Littenberg Krumholz & Mentlik, LLP
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The Federal Circuit examined whether a patent claim requiring return information to be initiated "without assistance by a user" excludes scenarios where users establish internet connections. The court's interpretation of this claim language and its analysis of the specification and prosecution history determined the validity of patents covering technology for recovering lost or stolen computers.

United StatesIntellectual Property
Lina Jlelaty
Lina Jlelaty
Gabriela Soskind
Gabriela Soskind
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In Hafeman v. Google LLC, 177 F.4th 1191 (Fed. Cir. 2026), the Federal Circuit affirmed a decision of the Patent Trial and Appeal Board invalidating claims of Hafeman’s patents as obvious. The patents are directed to the recovery of lost or stolen computers by displaying return information before or together with a lock screen. After Hafeman sued LG Electronics over devices preloaded with Google’s and Microsoft’s “Find My Device” features, Google and Microsoft petitioned for inter partes review of the patents.

The appeal turned on the claimed step of “initiating or changing return information which appears on the display through remote communication without assistance by a user with the computer.” Hafeman argued that “without assistance by a user” required that the user do nothing beyond turning on the computer. Based on this interpretation, Hafeman argued that the cited reference relied upon for this feature did not teach or suggest this feature because the cited reference

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