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Digital Messaging and Data Processing Patent Claims Survive Section 101/Alice Challenge

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For the second day in a row, this blog focuses on a case upholding the patent-eligibility, under 35 U.S.C. § 101, of patent claims that recite processing and transmitting data.  In Signal IP, Inc. v. American Honda Motor Co., Inc., No. 2-14-cv-02454 (CD Cal., March 22, 2016), the court upheld the patent-eligibility of claims of US Patent No. 5,954,775, directed to messages with different data types, and US Patent No. 5,714,927, directed to improvements in detecting vehicle radar blind spot coverage. This case is even more notable than the ContourMed case discussed yesterday, because here the court’s holding came on a motion for summary judgment, and was dispositive.  But these and other cases upholding patent-eligibility are significant because they bely an approach often taken by other courts and by the US Patent and Trademark Office during patent prosecution.  That is, USPTO examiners often reject claims under Section 101 if the claims recite data…

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