The Federal Circuit has triggered another debate over the proper scope of patent eligibility law. On June 11, a panel majority issued a precedential decision affirming the Alice invalidation of a digital camera patent asserted by inventors Yanbin Yu and Zhongxuan Zhang against Apple and Samsung, ruling that the patent was merely implementing the abstract idea of “taking two pictures . . . and using one picture to enhance the other in some way” using generic components rather than claiming a technological improvement. However, Circuit Judge Pauline Newman dissented, arguing that the majority’s decision improperly erodes the boundaries between patent eligibility and novelty/obviousness—and that the majority was wrong to apply Alice to what amounted to a mechanical invention.

Roughly a month after a “Scramoge, Ltd.” accused Samsung of infringing three former LG Innotek patents, generally related to wireless power transfer, Scramoge Technology Limited has filed suit against Apple (6:21-cv-00579) over patents from the same portfolio. Scramoge again targets in a Western District of Texas complaint wireless charging functionality in various products, this time including AirPods, Apple Watches, and iPhones.

Dismissals without prejudice have ended separate cases filed earlier this year by Pineapple34, LLC against Dell, Hon Hai Precision Industry (Dynabook), LG Electronics (LGE), Microsoft, Panasonic, and Sony. Those departures left active only the Western District of Texas suit against Alphabet (Google)—until late last week, when Pineapple34 sued Acer (6:21-cv-00580) and Fujitsu (6:21-cv-00581), both in the Western District of Texas as well. The plaintiff targets each over the support of computer peripherals and the Windows Find My Device software in the new defendants’ respective laptops and tablets.

Smart Mobile Technologies LLC (SMT), an entity formed in Delaware nearly a year ago, has launched a wireless communications campaign, suing Apple (6:21-cv-00603) in the Western District of Texas for the alleged infringement of 13 patents. The plaintiff targets the provision of a wide variety of devices (Apple TVs, Apple Watches, iPads, iPhones, iPads, etc.) that facilitate “dynamically switching” between networks of different types, i.e., Wi-Fi and cellular networks. SMT alleges that Apple has had notice of at least some of the patents since 2015 when a patent advisory firm was “engaged to assist with the divestment of certain patents and patent applications owned by a prior owner of the patents”.

The past few weeks have seen at least three NPEs file complaints before the International Trade Commission (ITC). Most recently, Proven Networks, LLC filed a May 28 complaint (the NPE’s first to date before the ITC) proposing as respondents Arista Networks, HP Enterprise (Aruba Networks), Cisco, Dell, F5 Networks, Juniper Networks, and Palo Alto Networks and targeting “certain networking devices, computers, and components thereof” (337-TA-3550).

Last August, the Federal Circuit rejected an appeal filed by TCL (TCT Mobile) from a judgment based on a jury verdict against it—and in favor of Godo Kaisha IP Bridge 1, a subsidiary of Japanese firm IP Bridge, Inc.—finding no error in the Delaware trial judge’s submission to the jury of questions whether the asserted patent claims are “essential to mandatory aspects of the Long-Term Evolution (‘LTE’) standard” and whether the accused products practice that standard. Further appeals exhausted, that $950K verdict stands. The same plaintiff has now sued Ericsson (2:21-cv-00213) and Nokia (2:21-cv-00215) under similar theories, this time in the Eastern District of Texas.

R2 Solutions LLC, an Acacia Research Corporation plaintiff, has sued iHeartMedia (6:21-cv-00552) and Roku (6:21-cv-00553) in the Western District of Texas over the provision of their respective streaming services, targeting certain features related to searching and search ranking. Two of the eight patents-in-campaign, from among the roughly 2,500 former Yahoo patents that Acacia acquired last year through Excalibur IP, LLC, are asserted against each defendant, with iHeartMedia hit with a third such patent.

Inventor-backed Optinetix Inc. has filed its first litigation, suing Amazon (Whole Foods) (4:21-cv-00423), Bed Bath & Beyond (1:21-cv-00292), HEB (1:21-cv-00273), Jo-Ann Stores (1:21-cv-00274), Kohl’s (1:21-cv-00275), Sprouts Farmers Market (1:21-cv-00291), Target (1:21-cv-00276), and Walgreen (1:21-cv-00293), all in the Eastern District of Texas, over mobile apps that support the distribution of digital coupons. The sole patent-in-suit generally relates to redeeming a digital coupon by reading “digital information” that is captured and stored on a mobile device.

Display Vectors, LLC has expanded what appears to be its sole litigation campaign, filing suit against Jazzy Electronics (Sound Around) (1:21-cv-03230) in the Eastern District of New York; HP (6:21-cv-00573) and LG Electronics (LGE) (6:21-cv-00572) in the Western District of Texas; and Lenovo (1:21-cv-00828) in the District of Delaware. The new complaints respectively target with three patents acquired from Intellectual Ventures LLC (IV) the hinge assembly, the double-sided display, and touch screen interface adjustments in laptops, smartphones, and/or other devices.

Its 2019 suits stayed to await the outcome of several inter partes reviews (IPRs) of the patents there in suit, Parus Holdings, Inc. has sued prior defendant Alphabet (Google) (6:21-cv-00570) and new defendant Microsoft (6:21-cv-00571), asserting overlapping subsets of three patents from the same family. The plaintiff again targets the provision of products that feature virtual assistants: for Google, the incorporation of Google Assistant in its various Chromecast, Fitbit, Google Glass, Nest, Pixel, and Stadia products; and for Microsoft, the incorporation of Cortana in its Microsoft Surface, Microsoft Windows 10, and Microsoft Windows 10 Mobile products.