Monday, August 01, 2016

Electric Power Group loses on 101 issue

This case involves the eligibility for patenting, under
35 U.S.C. § 101, of certain claims of three of Electric
Power Group, LLC’s patents, U.S. Patent Nos. 7,233,843;
8,060,259; and 8,401,710. Those patents describe and
claim systems and methods for performing real-time
performance monitoring of an electric power grid by
collecting data from multiple data sources, analyzing the
data, and displaying the results. See ’710 patent, col. 1,
lines 27–30; id., col. 2, lines 43–49. Electric Power Group
sued Alstom S.A., Alstom Grid, Inc., Psymetrix Limited,
and Alstom Limited (collectively, Alstom) in the Central
District of California, alleging infringement of various
claims of the three patents. The district court granted
Alstom summary judgment that the subject matter of
Electric Power Group’s asserted patent claims fails the
tests for patent eligibility under governing precedent.
We affirm. Though lengthy and numerous, the claims
do not go beyond requiring the collection, analysis, and
display of available information in a particular field,
stating those functions in general terms, without limiting
them to technical means for performing the functions that
are arguably an advance over conventional computer and
network technology. The claims, defining a desirable
information-based result and not limited to inventive
means of achieving the result, fail under § 101.


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