Graphical User Interface Menu Structure Found to be Patent-Eligible Subject Matter in US

On January 25, 2018, in a 2:1 split decision, the US Federal Circuit released its decision in Core Wireless Licensing v LG Electronics Inc, affirming the decision of the United States District Court for the Eastern District of Texas. The Federal Circuit upheld the District Court’s finding that US Patent Numbers 8,713,476, 8,434,020, and 6,415,164 (the Patents) claimed eligible subject matter.

The Patents, in essence, are directed to an improved graphical user interface for small display electronic devices. LG Electronics challenged the Patents arguing that they were improperly directed to an “abstract idea”. The District Court disagreed, finding the Patents’ claims to be directed to an improvement to a computer system, or more specifically to “displaying an application summary window while the application is in an unlaunched state”.

On appeal, the Federal Circuit court affirmed the decision of the District Court finding the claims to be directed towards patent-eligible subject matter. According to the Federal Circuit:

[t]hese limitations disclose a specific manner of displaying a limited set of information to the user, rather than using conventional user interface methods to display a generic index on a computer […] these claims recite a specific improvement over prior systems, resulting in an improved user interface for electronic devices.

All three judges agreed with this finding. Where the opinion of the dissenting judge differed from that of the majority was with respect to the definition of “unlaunched state”. The majority construed this term to mean “not displayed” where the dissent construed this term to mean “not running”. The construction of this definition could have potentially affected infringement and anticipation issues.

Additional commentary is available here.

Summary By: Jae Morris