On March 5, 2018, the US District Court for the Northern District of California (Court) released its decision in in Immersion Corp v Fitbit, Inc, partially granting Fitbit’s motion to dismiss a patent infringement lawsuit. Immersion Corporation alleged that Fitbit infringed upon the claims of three of their patents, specifically US Patent Numbers 8,059,105 (‘105 Patent), 8,351,299 (‘299 Patent), and 8,638,301 (‘301 Patent). Fitbit contended that these patents are invalid as their claims do not cover patent-eligible subject matter under 35 USC § 101.
The Court evaluated the patent claims according to the test as set out in Alice Corporation v CLS Bank International (Alice). Step one of the Alice framework directs the Court to assess “whether the claims at issue are directed to [an abstract idea]”. If the claimed subject matter is found to be abstract then the Court is to proceed on to the second step which asks whether the claim limitations “transform the claims into a patent-eligible application”.
With respect the ‘105 and ‘299 Patents, the Court concluded that both patents were not directed to an abstract idea at Alice step 1 and denied Fitbit’s motion to dismiss. According to the Court, the claimed subject matter of the ‘105 Patent was directed “to a haptic feedback device” and the ‘299 Patent was directed to “haptic notification”.
Regarding the ‘301 Patent, the Court concluded that the claims were directed to an abstract idea at Alice step 1. At Alice step 2, the Court found that there was no inventive concept and that the claims amounted to nothing more than “gathering and processing data” and “generic data analysis”. Consequently, the Court dismissed Immersion’s claims with respect to the ‘301 Patent.
Additional commentary is available here.
Summary By: Jae Morris
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