Signal Lost: Federal Circuit Says "Combining And Decoding" Doesn't Meet Section 101 Eligibility

The U.S. Court of Appeals for the Federal Circuit affirmed a district court judgment holding asserted claims of U.S. Patent No. 8,139,652 ineligible under 35 U.S.C. § 101 in Technology in Ariscale, LLC v. Razer USA Ltd., concluding the claims are directed to an abstract idea and lack an inventive concept.

The panel (Sharon Prost, Jimmie Reyna, Tiffany Cunningham) adopted a straightforward Alice/Mayo analysis: The claims recite receiving, manipulating and decoding data using generic computer functionality, and neither their framing nor the asserted order of steps transforms them into a patent-eligible application. The court, as is typical, refused to import performance "improvements" from the specification where the claims do not capture the asserted technical details.