Huawei Technologies Co., Ltd. et al v. Samsung Electronics Co., Ltd. et al, 3-16-cv-02787 (CAND November 21, 2016, Order) (Orrick, USDJ)
Wednesday, November 23, 2016
Patent for Reducing Signal Interference on Mobile Devices Not Invalid Under 35 U.S.C. § 101
The court denied defendants' motion to dismiss on the ground that one of plaintiff’s patents for reducing signal interference on mobile devices encompassed unpatentable subject matter because the asserted claims were not directed toward an abstract idea. "[Defendant] argues that the [patent] is directed to a mathematical equation because its claimed advance over the prior art is the inclusion of a specific set of 16 cyclic shift intervals, which [defendant] deems 'math.'. . . [T]he [patent] claims are directed to a specific improvement in cellular communications, and not an abstract idea or mathematical formula. . . . While the improvement necessarily relies on math because the low signal overload depends on the limited set of cyclic shift intervals, itself derived from mathematical equations and variables dictated by a cell’s size, that reliance does not render it ineligible for a patent. . . . The [patent] does not attempt to claim a mathematical formula. It discloses a method that uses a predefined set of numbers -- itself derived from an equation, but not occurring in the natural environment -- to enable a mobile device to more efficiently synchronize with a base station. This advance entails more than an abstract idea or 'just math.'"