Federal Circuit Nixes Claims for Garage Door Opener as Abstract Under Alice

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    Federal Circuit Nixes Claims for Garage Door Opener as Abstract Under Alice

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    “Wireless communication cannot be an inventive concept here, because it is the abstract idea that the claims are directed to.” – Federal Circuit Judge Raymond Chen

    A Federal Circuit panel comprising Judges Lourie, O’Malley and Chen issued a precedential opinion yesterday, August 21, in part reversing a district court’s finding that certain claims of Chamberlain Group, Inc.’s (CGI’s) patent for a “moveable barrier operator” (for example, a garage door opener) were not abstract under Section 101.

    The representative claim 1 of U.S. Patent No. 7,224,275 (the ‘275 patent) recites:

  • A movable barrier operator comprising:
  • a controller having a plurality of potential operational status conditions defined, at least in part, by a plurality of operating states;

    a movable barrier interface that is operably coupled to the controller;

    a wireless status condition data transmitter that is operably coupled to the controller, wherein the wireless status condition data transmitter transmits a status condition signal that:

    corresponds to a present operational status condition defined, at least in part, by at least two operating states from the plurality of operating states; and comprises an identifier that is at least relatively unique to the movable barrier operator, such that the status condition signal substantially uniquely identifies the movable barrier operator.

    Distinguishing Core Wireless

    The United States District Court for the Northern District of…

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