Inventions With Specific Improvements To Existing Technologies Are Not Invalid Under 35 U.S.C. § 101

Last Month at the Federal Circuit - January 2011

Judges: Rader (author), Newman, Plager
[Appealed from D. Ariz., Judge Jones]

In Research Corp. Technologies v. Microsoft Corp., No. 10-1037 (Fed. Cir. Dec. 8, 2010), the Federal Circuit reversed-in-part and affirmed-in-part the district court's judgment, ruling in favor of plaintiff Research Corporation Technologies, Inc. ("RCT"). Specifically, the Court reversed the district court's entry of SJ invalidating claims in U.S. Patent Nos. 5,111,310 ("the '310 patent") and 5,341,228 ("the '228 patent") under 35 U.S.C. § 101 and denying an earlier filing date to U.S. Patent No. 5,477,305 ("the '305 patent"). The Court affirmed the district court's decision that claims 4 and 63 of U.S. Patent No. 5,726,772 ("the '772 patent") are not entitled to the earlier filing date.