Today the Federal Circuit released a precedential opinion affirming a decision of ineligibility in a patent case appealed from the United States District Court for the Northern District of California. Judge Newman dissented. The court also released two nonprecedential opinions in cases appealed from the Merit Systems Protection Board and a Rule 36 judgment. Here are the introductions to the opinions and a link to the Rule 36 judgment.

Yu v. Apple Inc. (Precedential)

Yanbin Yu and Zhongxuan Zhang (collectively, “Yu”) sued Apple and Samsung (collectively, “Defendants”), alleging that Defendants infringed claims 1, 2, and 4 of U.S. Patent No. 6,611,289 (“the ’289 patent”). The district court granted Defendants’ motion to dismiss on the basis that the asserted claims were invalid under 35 U.S.C. § 101. Yu appeals. Because the district court did not err, we affirm.

Newman, Circuit Judge, dissenting.

The invention described and claimed in U.S. Patent No. 6,611,289 (“the ’289 patent”) is a digital camera having two lenses mounted in front of separate image sensors, with analog to digital conversion circuitry, a memory that stores the images, and a digital processor that enhances the images. This camera is a mechanical and electronic device of defined structure and mechanism; it is not an “abstract idea.” Observation of the claims makes clear that they are for a specific digital camera . . . .

The ’289 patent specification states that the digital camera described therein achieves superior image definition. A statement of purpose or advantage does not convert a device into an abstract idea. From the court’s further enlargement of Section 101 to deny access to patenting, and further obfuscation of the statute, I respectfully dissent.

Gossage v. Merit Systems Protection Board (Nonprecedential)

Henry E. Gossage appeals from the decision of the Merit Systems Protection Board (“Board”) denying his request for corrective action. The Board found that Gossage is barred by collateral estoppel from relitigating the untimeliness of the administrative complaint that he filed with the United States Department of Labor (“DOL”). See Gossage v. OPM, No. SF-3330-20-0625-I-1, 2020 WL 6877635 (M.S.P.B. Nov. 19, 2020); SAppx. 1–15. For the reasons below, we affirm.

Stern v. Department of Veteran Affairs (Nonprecedential)

Erin Stern appeals the Merit Systems Protection Board’s (“Board”) dismissal of her hostile work environment claim for lack of jurisdiction. We affirm.

Rule 36 Judgment