US Courts of Appeal, Federal Circuit (CAFC). Decided: April 30, 2020
Uniloc USA, Inc., Uniloc Luxembourg S.A. and Uniloc 2017 LLC (collectively, Uniloc) sued LG Electronics USA, Inc., LG Electronics MobileComm U.S.A., Inc. and LG Electronics, Inc. (collectively, LG) in the United States District Court for the Northern District of California, alleging infringement of claims of U.S. Patent No. 6,993,049. LG moved to dismiss Uniloc¡¯s Second Amended Complaint arguing that the claims of the ¡¯049 patent are ineligible under 35 U.S.C. ¡× 101. And the district court granted LG¡¯s motion, determining that the asserted claims are directed to an abstract idea and do not recite an inventive concept. But CAFC reversed and remanded the lower court¡¯s decision holding that the claims were not directed to ineligible subject matter under ¡× 101.
The ¡¯049 patent is directed to a communication system comprising a primary station and at least one secondary station. In conventional systems such as Bluetooth networks, two devices sharing a common communication channel form ad hoc networks known as ¡°piconets.¡± To join a piconet, two sets of procedures, namely an ¡°inquiry¡± procedure and a ¡°page¡± procedure, need to be completed. The inquiry procedure allows a primary station to identify secondary stations and also allows secondary stations to issue a request to join the piconet. The page procedure in turn allows a primary station to invite secondary stations to join the piconet. Once a piconet is formed, the primary station ¡°polls¡± secondary stations to determine whether they have data to share over the communication channel. In conventional systems, primary stations alternate between sending inquiry messages to identify new secondary stations and polling secondary stations already connected to the piconet to determine whether they have information to transmit so that a secondary station could experience delays of tens of seconds both in initially joining a piconet and in transmitting data after entering park mode.more
LG Electronics, Inc. filed a trademark application to register QLED (in standard characters) on the Principal Register for goods including mobile phones, smart phones, laptop computers, Computers, tablet computers, and LED panels. The Trademark Examining Attorney originally refused registration on the ground that QLED is merely descriptive of Applicant¡¯s goods.
Then LG amended the application to seek registration on the Supplemental Register. But the Examining Attorney continued the the smae refusal, and also refused registration on the additional ground that QLED is generic and therefore incapable of distinguishing the identified goods.
When the Examining Attorney made both refusals final, LG filed a request for reconsideration, which the Examining Attorney denied. Applicant then appealed to TTAB (Trademark Trial and Appeal Board). more
We make every effort to understand our client¡¯s business and needs to provide creative solutions and services tailored to suit each individual client. We serve clients in a variety of industries inclusive of, but not limited to, Electronics and Semiconductors, Food and Beverage, Communications Technology, Biotechnology, Medical Devices, Pharmaceuti-cals, Software and Information Technology, Construction, Automotive, and Environmental Technology. Our clients range from large to small and medium sized companies to individual inventors.
We provide professional services to clients from searching prior art to filing and registering domestic patents, utility models, designs, and trademarks.
Although, it is important that a patent ultimately registers, we place greater significance in ensuring the content of the patent provides our client with broad protection. more