Background
TJTM Technologies, LLC owned the eight nine five eight eight five three patent, which covered a mobile device that suppresses incoming notifications when paired with a vehicle and sends an away message. TJTM sued Google for patent infringement, alleging that Android phone features preventing distracted driving infringed the patent. Google moved to dismiss, arguing the claims were ineligible under Section one zero one. The district court granted the motion, finding the claims directed to an abstract idea of screening notifications and lacking an inventive concept. TJTM amended its complaint but the district court again dismissed the case after finding the claim limitations were generic and well-known.
The court’s reasoning
The Federal Circuit agreed with the district court that the patent claims are ineligible under Section one zero one. The court rejected TJTM’s argument that the patent addressed a technological problem with a technological solution, noting that the invention merely recites a different mode of operation for a mobile phone without changing the underlying technology. The court found the claims directed to the abstract idea of adding a communication-suppression function to a phone. Regarding the second step of the Alice analysis, the court agreed that the claim limitations were generic and well-known components ordered in a conventional fashion. The court emphasized that merely applying an abstract idea to a particular technological environment is not enough to transform the idea into patent-eligible subject matter.
What it means going forward
This decision reinforces that software patents claiming to solve user experience problems by suppressing notifications on conventional devices are likely ineligible unless they recite specific improvements to computer functionality.