Holland & Knight LLP
Earlier in the month, the U.S. District Court for the District of Delaware ruled that U.S. Patent No. The court ruled that Section 101 made Patent No. 11,625,675 ineligible. The court found that the defendant’s motion for dismissal was not valid because the claimed invention “generally directed” to a system and a method for controlling electronic locking for locking a room within a building – an abstract concept – and didn’t contain an inventive idea. The court’s analysis is discussed below. The patent challenger has the initial burden to show that the group of related claims is substantially similar. However, the court noted the burden shifts to the patent holder to show that the eligibility of the purportedly representative claim does not affect the other relevant claims. The patent owner argued other claims required a “power source,” “a wireless receiver,” and “one of more capacitors that filters the signals …,”, but the court found “merely providing examples” of physical components did not demonstrate that they were not “substantially similar.” The court considered claim one as representative.
Alice Step One
The defendant argued that the claims “are directed to an abstract idea of authorizing access to a secure location upon verification of a user’s credentials.” The defendant argued that this mirrored the steps taken to receive and secure a package by a building concierge – “receive the request to unlock a locked door, authenticate the user requesting access, approve the request after authentication, and cause the lock unlock or indicate the user failed authentication.” As further evidence, the defendant referred the court to Figure. The plaintiff argued that the record did not show that concierges controlled access to storage areas using signals or codes for authenticating credentials – or had ever used electronic locks with circuitry as claimed by the patent. The court disagreed, saying that “there is no doubt that humans can and do perform the task of securing and verifying credentials… That claim one performs this task with computer equipment, and signals, does not change the nature of the job performed …”
The Plaintiff further argued that claim describes a device and is therefore patent-eligible. The court agreed that the claim describes a machine but “qualifying as a machine is not dispositive of whether a technology is patent-eligible,” citing Alice.
Finally, the plaintiff argued that the asserted claim is directed to “resolving the problem of a delivery person being unable to deliver a package because the door to the locker of the recipient will not open, because the locker is in use, the package is oversized, and there is no other locker available. “
The court, again, disagreed: “a holistic reading of claim one … does not support that the focus of the claim is on improving access to package storage areas regardless of whether a storage area associated with the door is in use …” and found the representative claim to be directed to an abstract concept.
Alice Step Two
The court found that the “language of the patent supports that several of the listed components are well-understood and used in conventional ways,” specifically pointing to the specification’s discussion of known electronic locks.
The plaintiff countered that even if the individual components were generic, the defendant did not show the claimed combination was conventional. The court rejected the defendant’s argument, saying that the components were organized logically. “
The court determined that the representative claim was not patent-eligible under Section 101.
Representative Claim One
1. A system comprising:
at least one electronic lock for locking a door of a storage room that is stationary and part of a building, the storage room being large enough to accommodate packages that are small, medium, and oversized;
a lock interface that is communicatively coupled to the at least one electronic lock, the lock interface having at least one processor that implements one or more machine instructions stored on at least one non-transitory computer readable medium;
wherein the one or more machine instructions, when implemented, cause the processor of the lock interface to implement a method including at least
receiving, at the lock interface from a terminal, a first signal associated with a delivery, requesting access by unlocking the door;
in response, sending from the lock interface to the at least one electronic lock, a second signal including at least a request to open the door;
opening the electronic lock, based on the request, and allowing the access through the door, regardless of whether a storage area associated with the door is in use and regardless of whether the package is small, medium, or oversized;
wherein the request includes at least a user identity and a code, wherein the method further includes, after receiving the first signal including the request,
verifying, by the lock interface, the request by authenticating the user identity and the code received from the terminal;
approving the request, by the lock interface, after the user identity and the code are successfully authenticated;
in response to the approving of the request, sending the second signal, from the lock interface to the at least one electronic lock, the second signal causing the at least one electronic lock to automatically unlock, the at least one electronic lock including a circuit that includes at least
a signal input port that is communicatively connected to at least one signal output port of the lock interface;
an electronic switch that, in response to the receiving of signals from the lock interface, causes electric current to flow through the at least one electronic lock;
the step of verifying, by the lock interface, the request further including at least
comparing, by the lock interface, the user identity and the code received from the terminal with data stored in the lock interface;
approving the request, by the lock interface, when the user identity and the code received match the data stored in the lock interface, and
rejecting the request, by the lock interface, when at least one of the user identity and the code received does not match the data stored in the lock interface; and
in response to the rejecting of the request, sending, from the lock interface to the terminal, a message indicating that the request is invalid.
As always, thank you for reading.
