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Why we think AI can be an inventor on a patent application

On April 18, 2023, we submitted a Supreme Court amicus brief expressing our encouragement for the justices to rule on the question of whether it is proper for an artificial intelligence (AI) to be an inventor on a patent...more

Who Owns Your ChatGPT Output? (Hint: Probably Not You)

ChatGPT is a large language model developed by OpenAI. It is based on the transformer architecture and trained on a massive dataset of text from the Internet. It has the ability to generate human-like text and can be used for...more

Simio, LLC v. FlexSim Software Products, Inc. (Fed. Cir. 2020)

This decision is bad.  Not an American Axle level of bad, but still quite far from good. Simio sued FlexSim in the District of Utah for alleged infringement of its U.S. Patent No. 8,156,468.  FlexSim moved for dismissal on...more

C R Bard Inc. v. AngioDynamics, Inc. (Fed. Cir. 2020)

One of the more intellectually dishonest aspects of current patent eligibility law is that it allows one to ignore certain claim elements when evaluating claims under 35 U.S.C. § 101.  In Mayo v. Prometheus, it was stated...more

On the Patent Eligibility of Graphical User Interfaces: Part II

This article is Part II of a study on the patent eligibility of graphical user interfaces.  Part I was published yesterday.  We continue from where we left off, with overviews of a handful of Federal Circuit § 101 decisions...more

On the Patent Eligibility of Graphical User Interfaces: Part I

The evolution of graphical user interfaces parallels the evolution of computing technology itself.  As computers grow more powerful and sophisticated, so does their ability to display cutting-edge representations of...more

USPTO Publishes Report on AI-Related Policies

Last year, the U.S. Patent and Trademark Office (USPTO) issued a request for comments (RFC) on patenting artificial intelligence (AI) based inventions.  Topics of the RFC included AI's impact on inventorship and ownership,...more

Federal Circuit Rules Public Key Cryptography Algorithm Invalid Under 35 U.S.C. § 101

Note:  The below is a sarcastic parody, in the spirit of our earlier sarcastic parodies. WASHINGTON D.C., June 23, 1984.  In a unanimous decision, the Federal Circuit has ruled U.S. Patent No. 4,405,829 invalid under 35...more

Packet Intelligence LLC v. NetScout Systems, Inc. (Fed. Cir. 2020)

Introduction - Packet Intelligence sued NetScout in the Eastern District of Texas, alleging infringement of U.S. Patent Nos. 6,665,725, 6,839,751, and 6,954,789.  The District Court ruled that all three patents were valid...more

Of Technical Tools and Problems: Going Beyond the Two-Prong Alice Test

It is abundantly clear that the Supreme Court's 2014 Alice Corp. v. CLS Bank decision has significantly changed the patent-eligibility landscape for business methods and some types of software inventions. For instance, in...more

Planet Bingo, LLC v. VKGS LLC (Fed. Cir. 2014)

Planet Bingo is the assignee of U.S. Patent Nos. 6,398,646 and 6,656,045, both directed to computer-implemented methods and systems for managing bingo games. Planet Bingo filed an infringement action in the United States...more

Supreme Court Hears Oral Argument in Alice Corp. v. CLS Bank Int'l

On Monday, March 31, the Supreme Court heard oral arguments in the closely-watched Alice Corp. v. CLS Bank Int'l case. The question presented was "[w]hether claims to computer-implemented inventions -- including claims to...more

Alice Corp. v. CLS Bank Int'l: Alice's Supreme Court Brief

On December 6th, the Supreme Court granted certiorari to a case that presents the question of "[w]hether claims to computer-implemented inventions -- including claims to systems and machines, processes, and items of...more

SmartGene, Inc. v. Advanced Biological Laboratories, SA (Fed. Cir. 2014)

While non-precedential, this recent Federal Circuit decision further illustrates the Court's thinking with regard to the patent-eligibility of computer-implemented inventions under 35 U.S.C. § 101, and provides a reminder...more

Accenture Global Services, GmbH v. Guidewire Software, Inc. (Fed. Cir. 2013)

Recipe for a contentious Federal Circuit decision: empanel two judges who have different understandings of the patent-eligibility of computer-related inventions, sprinkle in a claim or two that could be viewed as a pure...more

MBHB Snippets: Review of Developments in Intellectual Property Law - Volume 11, Issue 3 (Summer 2013): Not Just a Flook?:...

On May 10, 2013, the Federal Circuit handed down the much-anticipated en banc decision in CLS Bank Int'l v. Alice Corp. This case is perhaps the most important 35 U.S.C. § 101 jurisprudence regarding the patent eligibility of...more

Ultramercial, Inc. v. Hulu, LLC (Fed. Cir. 2013)

It has been just over a month since the Federal Circuit's fractured en banc ruling in CLS Bank Int'l v. Alice Corp. regarding patent-eligibility of computer-implemented inventions under 35 U.S.C. § 101. Last week, the Court...more

CLS Bank Int'l v. Alice Corp. (Fed. Cir. 2013) (en banc) -- Chief Judge Rader's Concurrence-in-part and Dissent-in-part

A previous post presented the background of this case, as well as Judge Lourie's plurality concurrence. As noted in that post, Alice's claimed inventions involved the reduction of settlement risk using a third-party...more

CLS Bank Int'l v. Alice Corp. (Fed. Cir. 2013) (en banc) -- Judge Lourie's Concurrence

On May 10, the Federal Circuit handed down a much anticipated en banc ruling regarding the patent eligibility of computer-implemented inventions under 35 U.S.C. § 101. In a per curiam opinion that is perhaps the most...more

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