Improved User Interface Survives Section 101 Challenges
In Core Wireless Licensin g S.A.R.L. v. LG Electronics, Inc., the Federal Circuit held that user interface claims are patent eligible under 35 U.S.C. § 101 because they “recite a specific improvement over prior systems, resulting in an improved user interface for electronic devices.” Core Wirele ss Licensing S.A.R.L. v. LG Elecs., Inc., 880 f . 3d 1356, 1363 (Fed. Cir. 2018). The court determined that the claims are directed to “a particular manner of summarizing and presenting information in electronic devices” and that the claims do not “us[e] conventional user interface methods to display a generic index on a computer.” Id.
Representative Claim 1 at issue in this case recites:
1. A computing device comprising a display screen, the computing device being configured to display on the screen a menu listing one or more applications, and additionally being configured to display on the screen an application summary that can be reached directly from the menu, wherein the application summary displays a limited list of data offered within the one or more applications, each of the data in the list being selectable to launch the respective application and enable the selected data to be seen within the respective application, and wherein the application summary is displayed while the one or more applications are in an un-launched state.
The district court focused on the claimed concepts of “application,” “summary window,” and “unlaunched state,” finding that these concepts are specific to devices like computers and cellphones. The district court further noted that even if the claims were directed to an abstract idea, they would still be patent eligible due to passing the machine-or-transformation test.
The Federal Circuit agreed with the district court that the claims are directed patentable subject matter, but arrived at this conclusion based upon a different analysis. To begin, the Federal Circuit acknowledged previous cases holding claims eligible based on system improvements (e.g., Enfish, Thales, Visual Memory, and Fin jan). The Federal Circuit found the Core Wireless claims similar, noting that they recite a specific improvement (e.g., “displaying a limited set of information to the user”) over conventional user interface methods, “resulting in an improved user interface for electronic devices.” Id.
In its analysis, the Federal Circuit pointed to claim limitations that disclose the specific manner of displaying a limited set of information to the user. The court looked to teachings in the specification that the claimed technology addresses problems with “efficiency of using the electronic device,” “particularly those with small screens.” Id. The claimed user interfaces allow a user to more quickly access data and applications in electronic devices, improving “[t]he speed of a user’s navigation through various views and windows.” Id.
Accordingly, the Federal Circuit determined that the claims were directed to “an improvement in the functioning of computers” and not to any abstract idea, and thus are patent eligible under step one of the eligibility analysis. This resolved the question, so the court did not proceed to step two.
The Federal Circuit did not address the district court’s reliance on the machine-or-transformation test as a path to patent-eligibility under the two-part Alice framework. Although the Federal Circuit’s decision on patent eligibility did not rely on this basis, it also did not preclude it as an option for establishing subject matter eligibility.
Nevertheless, based on its result that user interface claims are patent eligible and improve computer technology (by improving a user’s efficiency rather than the computer hardware’s own inherent efficiency), this case will likely become an important tool for those seeking eligibility under 101.