Apple tastes victory against Smartflash at Federal Circuit

Apple has emerged victorious at the US Court of Appeals for the Federal Circuit after it invalidated three patents owned by licensing company Smartflash.

Yesterday, March 1, the Federal Circuit found that the patents were invalid under section 101.

In 2013, Smartflash sued Apple at the US District Court for the Eastern District of Texas, alleging that Apple’s iTunes software infringed patents directed to accessing and storing downloaded songs, videos and games.

The patents concerned were US numbers 7,334,720; 8,118,221; and 8,336,772.

In early 2015, Apple was ordered to fork out $532.9 million to Smartflash after it was found to infringe the patents. During the trial, Apple had argued that the claims were invalid under section 101.

After trial, Apple asserted that the patent claims were ineligible, but the district court denied Apple’s motion and the company appealed.

Section 101 states that “whoever invents or discovers any new and useful process, machine, manufacture, or composition of matter, or any new and useful improvement thereof, may obtain a patent therefore, subject to the conditions and requirements of this title”.

The US Supreme Court, in interpreting the statute in Alice v CLS Bank, held that “laws of nature, natural phenomena, and abstract ideas” are not patentable.

Following Alice, the court found that the claims in this case were “all directed to the abstract idea of conditioning and controlling access to data based on payment”.

It added that the claims “fail to recite any inventive concepts sufficient to transform the abstract idea into a patent-eligible invention”, so the patents were invalid.

Did you enjoy reading this story?  Sign up to our free daily newsletters and get stories like this sent straight to your inbox.