Elec. Power Group, LLC v. Alstom S.A., No. 15-1778 (Fed. Cir. 2016)Annotate this Case
Electric Power’s patents describe and claim systems and methods for performing real-time performance monitoring of an electric power grid by collecting data from multiple data sources, analyzing the data, and displaying the results. Electric Power sued Alston, alleging infringement of various claims of the three patents. The district court granted Alstom summary judgment that the subject matter of the claims failed the tests for patent eligibility under 35 U.S.C. 101. The Federal Circuit affirmed. “Though lengthy and numerous, the claims do not go beyond requiring the collection, analysis, and display of available information in a particular field, stating those functions in general terms, without limiting them to technical means for performing the functions that are arguably an advance over conventional computer and network technology.” The claims, defining a desirable information-based result and not limited to inventive means of achieving the result, fail under section 101.