Please join us for the SoCal IP Institute meeting, Monday, December 20 at Noon. This activity is approved for 1 hour of MCLE credit. If you will be joining us, please RSVP to Amanda Jones by 9 am Monday.
We will be discussing the following:
Western Union Co. v. Moneygram Payment Systems, Inc., No. 10-1080 (Fed. Cir. Dec. 7, 2010) (case attached) After a district court decision that several Western Union patents related to so-called “formless” wire transfers were not invalid as obvious and that Moneygram infringed, Moneygram sought review of the infringement, obviousness and claim construction decisions. The Federal Circuit reversed on the basis that each of the remaining asserted patents were invalid as obvious over prior art before the district court. The case is interesting as a substantive Federal Circuit discussion of obviousness after KSR.
Research Corp. Technologies, Inc. v. Microsoft Corp., No. 10-1037 (Fed. Cir. Dec. 8, 2010) (case attached) This case relates to digital image halftoning. After a district court decision that several Research Corp. patents asserted against Microsoft were invalid as failing to claim patent-eligible subject matter and that other patents were not entitled to earlier effective filing dates, the Federal Circuit reversed the statutory subject-matter decision, reversed the decision regarding the effective filing date of one patent and affirmed the effective filing date of one other. The case is most interesting as a discussion regarding statutory subject matter of process claims.