Rule 36 Affirms § 101 Invalidity, Sidesteps Party Challenge

In Polar Electro Oy v. Suunto Oy, No. 24-1801 (Fed. Cir. Dec. 3, 2025), the Federal Circuit summarily affirmed, under Rule 36, a district court judgment holding U.S. Patent No. 6,537,227 (the ’227 patent) invalid as directed to patent-ineligible subject matter. The ’227 patent is directed to a wearable heart-rate monitor and an associated method for assessing energy expenditure during physical exercise. The district court applied the two-step Alice framework. At step one, the district court determined that the claims were directed to an abstract idea related to mental processes, reasoning that its recited steps of measuring, obtaining, and assessing amounted to no more than gathering information and performing a calculation that did not require a computer. At step two, the district court found no inventive concept, rejecting as insufficient an expert declaration that the claims employed an “oddball” approach by working backward from VO₂max without regard to the source of that value.