Chamberlain Group, Inc. v. Techtronic Industries Co. Ltd., No. 18-2103 (Fed. Cir. 2019)
Annotate this CaseCGI’s 275 patent relates to an apparatus and method for communicating information about the status of a movable barrier, for example, a garage door. The district court rejected TTI’s allegation that the asserted claims are directed to the abstract idea of wireless transmission of content and, therefore, directed to patent-ineligible subject matter under 35 U.S.C. 101, finding the claims directed “to garage door openers that wirelessly transmit status information” and constituted “a particular improvement over prior art which uses a particular manner of sending and experiencing data.” The court granted CGI’s motions for enhanced damages and attorney fees. The Federal Circuit reversed in part, concluding that three claims are directed to an abstract idea and are patent-ineligible. No inventive concept exists in the asserted claims sufficient to transform the abstract idea of communicating status information about a system into a patent-eligible application of that idea. The court affirmed the jury’s verdict with respect to its finding of no anticipation of three claims of CGI’s 966 patent, directed to a rechargeable battery backup system for a barrier movement operator. The court vacated the injunction and awards of enhanced damages and attorney fees and remanded for reconsideration of enhanced damages and attorney fees with respect to only the 966 patent.
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