Technology Development and Licensing, LLC v. General Instrument Corporation, 1-07-cv-04512 (ILND December 6, 2016, Order) (Lefkow, USDJ)
Thursday, December 8, 2016
Television Control System Patent Invalid Under 35 U.S.C. § 101
The court granted defendant's motion for summary judgment that plaintiff's television control system patent encompassed unpatentable subject matter and found that the claims lacked an inventive concept. "[T]he claims are limited to a particular technological context: 'devices for viewer control of a television receiver,' and the inventor does not profess that the claimed system is innovative in the wider context of electronic circuitry or micro-processing. . . . [T]he specification describes the problem being solved as the confusion and inconvenience that resulted from the advent of cable and satellite television services with their multiplicity of channels and unfamiliar and inconsistent numbering systems. . . . In short, the need was to put a conversion chart on a remote control in an easily usable format, a task that would not suggest that innovative technology would be required to accomplish. . . . The claimed system is readily comparable to the electronic map found unpatentable for lack of an inventive concept in Peschke Map Technologies LLC v. Rouse Properties Inc., 168 F. Supp. 3d 881 (E.D. Va. 2016)."