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Federal Circuit Partially Affirms Alice Win for HP in Inventor’s Document Management Suit

February 9, 2018

The Federal Circuit has partially upheld a summary judgment of validity for HP in a suit brought by inventor Steven E. Berkheimer over document management software (1:12-cv-09023). In a decision issued on February 8, the Federal Circuit affirmed part of a December 2016 summary judgment in which the lower court held that four of the asserted patent’s claims are invalid under Alice as impermissibly directed to the abstract idea of “collecting, organizing, comparing, and presenting data” (2017-1437). However, the Federal Circuit reversed and remanded as to the invalidation of four other claims under Alice, holding that the patent’s specification raised questions of fact as to the inventiveness of those claims such that summary judgment was premature. In that same decision, the Federal Circuit also affirmed an August 2015 summary judgment that another ten claims from the same patent are invalid as indefinite.


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