On January 13, 2021, the Federal Circuit issued a decision in iLife Technologies, Inc. v. Nintendo of America, Inc. (available here). The decision affirmed Chief Judge Lynn’s decision that, under Alice, iLife’s patent claim at issue was directed to patent ineligible subject matter.
Under Alice step 1, the Court held “that these claims are directed to the abstract idea of gathering, processing and transmitting data.” “[C]laim 1 . . . is not focused on a specific means or method to improve motion sensor systems, nor is it directed to a specific physical configuration of sensors.”
Under Alice step 2, the Court held that “[a]side from the abstract idea, the claim recites only generic computer components, including a sensor, a processor, and a communication device. The specification’s description of these elements confirms they are generic.” “[C]laim 1 does not recite any unconventional means or method for configuring or processing that information to distinguish body movement based on dynamic and static acceleration. Therefore, we conclude that claim 1’s mere call for sensing and processing static and dynamic acceleration information using generic components does not transform the nature of claim 1 into patent eligible subject matter.”