Hawk Technology Systems, LLC sued Appellee Castle Retail, LLC, No. 22-1222 (Fed. Cir. 2023)
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Hawk’s patent, titled “high-quality, reduced data rate streaming video product and monitoring system,” relates to a method of viewing multiple simultaneously displayed and stored video images on a remote viewing device of a video surveillance system. Hawk sued Castle for patent infringement based on Castle’s use of security surveillance video operations in its grocery stores. Castle argued that the asserted claims were directed to ineligible subject matter and invalid under 35 U.S.C. 101.
The Federal Circuit affirmed the dismissal of the suit. The patent claims were directed to the abstract idea of storing and displaying video and failed to provide an inventive step that transformed that abstract idea into a patent-eligible invention. The claims do not disclose performing any “special data conversion” or otherwise describe how the alleged goal of “conserving bandwidth while preserving data” is achieved. Nor do the claims (or specification) explain “what th[e] [claimed] parameters are or how they should be manipulated.” The claims, “read in light of the specification, do not show a technological improvement in video storage and display because the limitations can be implemented using generic computer elements.” The “specification and claims do not explain or show how the monitoring and storage is improved, except by using already existing computer and camera technology.”
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