Improved User Experience Does Not Improve Computer Functionality Under Alice, Court Rules
Intellectual Property Partner Anthony Fuga authored an article recapping a recent decision from the U.S. Court of Appeals for the Federal Circuit affirming a lower court ruling that found an asserted patent ineligible under Section 101. The asserted patent claim related to making object-oriented simulations more user-friendly by allowing users to build simulations with graphics instead of programming. Under the two-step Alice test, the Federal Circuit found the claim was directed to an abstract idea without any inventive concept or meaningful application to save its eligibility. The Federal Circuit also affirmed the lower court's decision denying the plaintiff leave to amend its complaint based on the then-recent Cellspin v. Fitbit decision. In this article, Mr. Fuga analyzes the Federal Circuit's reasoning. The article was published in the Intellectual Property & Technology Law Journal.