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    Chamberlain Petitions SCOTUS to Review CAFC’s “Refusal to Assess Claims as a Whole” in Garage Door Opener Case

    Garage Door Remote Is Not Working Consistently

    “Citing many cases where industries have asked the Supreme Court to step in [on Section 101], Chamberlain noted that this is “an innovation emergency” that is undermining innovation and investment.”

    On May 15, the Chamberlain Group Inc. filed a petition for a writ of certiorari asking the U.S. Supreme Court to review the U.S. Court of Appeals for the Federal Circuit’s (CAFC) decision reversing a district court’s holding that Chamberlain’s claims covering a “moveable barrier operator” were patent-eligible under Section 101. If the Supreme Court grants review, it will consider whether the Federal Circuit “improperly expanded § 101’s narrow implicit exceptions by failing to properly assess Chamberlain’s claims ‘as a whole,’ where the claims recite an improvement to a machine and leave ample room for other inventors to apply any underlying abstract principles in different ways.”

    Federal Circuit Reasoning

    On appeal, the CAFC found the disputed claims of U.S. Patent No. 7,224,275 (the ‘275 patent) to be ineligible because “wireless transmission” was the only element of the claims that was inventive over the prior art. The CAFC noted that “transmitting information wirelessly was conventional at the time the patent was filed and could be performed with off-the-shelf technology.” Thus, since “wireless communication cannot be an inventive concept here, because it is the abstract idea that the claims are directed to,” the Court…

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