Apple and Samsung in camera suit win, Newman dissents
The US Court of Appeals for the Federal Circuit has affirmed a lower court’s dismissal of a lawsuit alleging that Apple and Samsung had infringed on existing patents with their multi-camera features.
The decision was handed down on Friday, June 11, affirming the US District Court for the Northern District of California’s ruling that claims of US patent 6,611,289 (‘289) were linked to an “the abstract idea of taking two pictures and using those pictures to enhance each other” and lacked an inventive concept.
Yanbin Yu and Zhongxuan Zhang, the inventors of the ‘289 patent, first filed the lawsuit against Apple and Samsung with the district court in 2018, leading them to fire back with a joint motion to dismiss, claiming the patent was ineligible under Section 101.
While the decision was affirmed by the appellate court, Judge Pauline Newman offered a dissenting opinion, taking issue with the district court’s characterisation of the claim as an “abstract idea”.
“This camera is a mechanical and electronic device of defined structure and mechanism; it is not an ‘abstract idea’... The camera of the ’289 patent may or may not ultimately satisfy all the substantive requirements of patentability, for this is an active field of technology. However, that does not convert a mechanical/electronic device into an abstract idea,” Newman argued.
The remaining circuit judges Prost and Taranto agreed with the district court that claim 1 of the patent was related to an abstract idea, finding Yu’s appeal arguments unpersuasive.
Eligibility defence
In defence of the patent, Yu said that the asserted claims were directed to patent-eligible improvements in digital camera functionality and the patent claims point towards a specific four-lens and four image-sensor configuration to make it patentable over prior art.
Prost wrote: “In these circumstances, the mismatch between the specification statements that Yu points to and the breadth of claim 1 underscores that the focus of the claimed advance is the abstract idea and not the particular configuration discussed in the specification that allegedly departs from the prior art.”
Yu also argued that the district court erred in the pleadings stage, making “adverse findings of fact” and failing to accept certain allegations in the complaint. According to Yu, the court should not have considered the practice of “using multiple images” as well known, that it should not have ruled on the technology without expert opinion and that it had “improperly disregarded” Yu’s allegations of patent ineligibility.
In response, Prost called Yu’s arguments “misplaced”, and that there was no error in the district court's ruling, despite Yu’s objections.
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