Koninklijke KPN N.V. v. Gemalto M2M GMBH, No. 18-1863 (Fed. Cir. 2019)Annotate this Case
KPN sued Gemalto for infringement of its 662 patent, which concerns “systemic error” in the physical transmission of information over the air, The district court found four claims patent-ineligible under 35 U.S.C. 101, as reciting no more than mere abstract data manipulation operations, such as “reordering data and generating additional data.” The Federal Circuit reversed. These claims are directed to an improved check data generating device that enables a data transmission error detection system to detect a specific type of error that prior art systems could not. The 662 patent solves prior art problems by varying the way check data is generated by varying the permutation applied to different data blocks. Varying the permutation for each data block reduces the chances that the same systematic error will produce the same defective check data across different data blocks. Claims 2–4 thus replace the prior art check data generator with an improved, dynamic check data generator that enables increased detection of systematic errors that recur across a series of transmitted data blocks. The appealed claims represent a nonabstract improvement in the functionality of an existing technological process and not simply an abstract idea of manipulating data.