Fresh From the Bench: Latest Federal Circuit Court Cases
CASE OF THE WEEK
Ronald Chandler v. Phoenix Services LLC, Appeal No. 2020-1848 (Fed. Cir. June 10, 2021)
In this week’s Case of the Week, the Federal Circuit addressed the ongoing question of its subject matter jurisdiction over cases involving patents, but that do not concern allegations of infringement or invalidity. In this week’s case, the Court determined that it lacked subject matter jurisdiction over an appeal from a Walker Process antitrust claim and transferred the appeal to the Fifth Circuit Court of Appeals. The Court narrowly distinguished a prior case involving a Walker Process claim where it held it did have subject matter jurisdiction.
Yanbin Yu v. Apple Inc., Appeal No. 2020-1760 (Fed. Cir. June 11, 2021)
In an appeal from the United States District Court for the Northern District of California, the Federal Circuit addressed whether the district court erred in finding that plaintiff’s asserted patent claims were patent-ineligible. The Court affirmed the district court’s decision, holding that plaintiff’s patent claims—which described taking two pictures and using one picture to enhance the other in some way—constituted an abstract idea, and that the claims did not include an inventive concept sufficient to transform the abstract idea into a patent-eligible invention. Judge Newman dissented, arguing that plaintiff’s patent claims warranted review under the substantive criteria of patentability, including novelty and non-obviousness.