The U.S. Court of Appeals for the Federal Circuit (CAFC) recently upheld a California district court’s decision to dismiss a patent infringement case against Blippar.com. The case involved Mobile Acuity’s patents titled “Storing Information for Access Using a Captured Image.” Blippar.com filed a motion to dismiss, arguing that the asserted patent claims were ineligible under Section 101. The district court agreed with Blippar.com and dismissed the case.
On appeal, Mobile Acuity argued that the district court made several errors, including failing to recognize patent eligibility as an affirmative defense and treating certain claims as representative of all claims. However, the CAFC affirmed the district court’s decision, stating that the claims were directed to an abstract idea and lacked an inventive concept. The court also agreed with the district court’s denial of Mobile Acuity’s request to file a third amended complaint.
Overall, the CAFC’s decision highlights the importance of addressing patent eligibility issues early in litigation. It also emphasizes the need for patent applicants to ensure that their claims are not directed to abstract ideas without an inventive concept. This case serves as a reminder of the challenges that patentees may face in defending their patents against eligibility challenges and the importance of crafting strong and specific patent claims.