Power Group, LLC v. Alstom S.A.

August 01, 2016

Federal Circuit No. 2015-1778
Author: Hyunseok Park
Electric Power Group sued Alstom, alleging infringement of various claims of the three patents. The district court granted Alstom summary judgment that the subject matter of Electric Power Group’s asserted patent claims is not patent eligible.  Electric Power Group appealed.

The claim on appeal was directed to a method of detecting events on an interconnected electric power grid in real time over a wide area and automatically analyzing the events on the interconnected electric power grid.  The claim recited collecting information, analyzing it and displaying results of the collection and analysis.

The Federal Circuit found that information is an intangible, and thus the features relating to collecting and analyzing information are abstract ideas.  The Court distinguished the claim at issue from the claim in Enfish.  In particular, the Court stated that Enfish's claim focuses on a specific improvement-a particular database technique-in how computers could carry out one of their basic functions of storage and retrieval of data.  In contrast, the Court found that the focus of the claim at issue is not on such an improvement in computers as tools, but on certain independently abstract ideas that use computers as tools.  Therefore, the Court found that the claim at issue is directed to a judicial exception.

In addition, the Court found that the particular elements of the claim, considered both individually and as an ordered combination, do not add enough to transform the nature of the claim into a patent-eligible application, and affirmed the judgement of the district court.