This morning the Federal Circuit released a nonprecedential opinion in a patent case appealed from a district court. The opinion addresses eligibility. The Federal Circuit also released a nonprecedential order granting a joint motion to remand a case back to a district court. Here is the introduction to the opinion and a link to the order.
TJTM Technologies, LLC v. Google LLC (Nonprecedential)
TJTM Technologies, LLC (TJTM) appeals the United States District Court for the Northern District of California’s grant of Google LLC’s (Google) motion to dismiss. TJTM Techs., LLC v. Google LLC, No. 24-CV-01232-TLT, 2024 WL 5106443, at *6 (N.D. Cal. Oct. 22, 2024) (Decision). Below, the district court determined that representative claim 1 of TJTM’s U.S. Patent No. 8,958,853 (’853 patent) (1) is directed to an ineligible abstract idea and (2) lacks an inventive concept. Thus, the district court determined that the ’853 patent claims were ineligible under 35 U.S.C. § 101, and TJTM could not survive a motion to dismiss its patent infringement action. Because we agree that the ’853 patent claims are ineligible under § 101, we affirm.