Federal Circuit Patent Update – March 12, 2019

Precedential Federal Circuit Opinions

1. UNIVERSITY OF FLORIDA RESEARCH v. GENERAL ELECTRIC COMPANY [OPINION - PRECEDENTIAL] (2018-1284, 2/26/19) (Prost, Moore, Wallach)
   
   Moore, J. Affirming grant of motion to dismiss because claims are directed to ineligible subject matter. "On its face, the [asserted] patent seeks to automate 'pen and paper methodologies' to conserve human resources and minimize errors. This is a quintessential 'do it on a computer' patent: it acknowledges that data from bedside machines was previously collected, analyzed, manipulated, and displayed manually, and it simply proposes doing so with a computer... That the automation can 'result in life altering consequences," [citation to patent omitted], is laudable, but it does not render it any less abstract. The [asserted] patent nowhere identifies, and we cannot see in the claims, any 'specific improvement to the way computers operate.'" Also finding that the patent owner waived sovereign