Federal Circuit Rules That Claims For Programmable Tiered Computer Memory Are Patent-Eligible

Visual Memory LLC v. NVIDIA Corp., No. 2016-2254 (Fed. Cir. Aug. 15, 2017)

The U.S. Court of Appeals for the Federal Circuit reversed a district court ruling dismissing a patent infringement action on the ground that the asserted claims were not patent-eligible under Alice Corp. Pty. v. CLS Bank Int'l, 134 S.Ct. 2347 (2014). The appeals court ruled that the claims were directed to an improved computer memory system, not merely to the abstract idea of categorical data storage. The court noted that any concerns that the patent claims did not provide enough detail about how the invention actually works is a question of enablement, 35 U.S.C. § 112(a), an issue separate from eligibility.