On September 3, 2020, Judge Connolly invalidated five asserted patents as patent ineligible on a single Rule 12 motion. In Sensormatic Electronics, LLC v. Wyze Labs, Inc., C.A. No. 19-1543-CFC, Judge Connolly granted defendant's motion for judgment on the pleadings, invalidating five of seven asserted patents (two of the seven were no longer being asserted).
The patents at issue involve "wireless surveillance systems for monitoring a target environment and methods of operating such systems" according to the ruling. Judge Connolly focused on the independent claims only, which the parties had agreed were representative of all asserted claims.
The Court found that the patents were directed to the abstract ideas of "wireless communications and remote surveillance" (emphasis added). A footnote explained that a combination of abstract ideas "does not create a non-abstract idea," citing Federal Circuit precedent. Interestingly, later in the ruling, the Court found that certain claims of the asserted patents embodied additional abstract ideas, including "classifying and storing digital images in an organized manner" and "translating information between different formats."
After finding that the generic, commercially available computer components recited in the claims and specification did not reveal an inventive concept, the Judge held the asserted patents ineligible.
Although the plaintiff argued that claim construction was necessary before the Court could rule on the Section 101 motion, it did not identify any specific claim construction issue. The Judge found it telling that in claim construction briefing, the plaintiff had asserted that no terms needed to be construed.
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