Case Summary of A Recent Decision of U.S. Court of Appeals for The Federal Circuit In The Case, “Core Wireless Licensing vs. LG Electronics”

This article summarises a recent judgment of United States Court of Appeals for the Federal Circuit dated 25th January 2018 in the case “Core Wireless Licensing S.A.R.L. v. LG Electronics, Inc., LG Electronics Mobile comm U.S.A., Inc.

Brief Insight into the Dispute:

The patents 8,713,476 (hereinafter referred to as “‘476”) and 8,434,020 (hereinafter referred to as “‘020”) owned by Core Wireless Licensing form the subject matter of this dispute. The dispute revolves around the claim of Core Wireless Licensing that these patents were infringed by LG and LG’s defence that both the patents direct to an ineligible subject matter (a mere abstract idea) under 35 U.S.C. § 101 hence, not patentable and there is no infringement.

Subject Matter of the Dispute:

The patents ‘476 and ‘020 of Core Wireless Licensing which were allegedly infringed by LG form the subject matter of the dispute. The patents revealed and claimed “improved display interfaces, particularly for electronic devices with small screens like mobile telephones. The improved interfaces allow a user to more quickly access desired data stored in, and functions of applications included in, the electronic devices.”

The ’476 and ’020 patent specifications are effectively identical and the functionality proposed by both the patents can be stated as “A computing device comprising a display screen, the computing device being configured to display on the screen a menu listing one or more applications, and additionally being configured to display on the screen an application summary that can be reached directly from the menu, wherein the application summary displays a limited list of data offered within the one or more applications, each of the data in the list being selectable to launch the respective application and enable the selected data to be seen within the respective application, and wherein the application summary is displayed while the one or more applications are in an un-launched state.”

Flow of Proceedings:

To avoid the trial, LG filed a motion for summary judgment for invalidity of the claims under 35 U.S.C. § 101, which was denied by the court. For the purposes of evaluating patent eligibility, the district court found claim of ’476 patent to be the representative of both the patents. It held that the claims are not directed to an abstract idea because, the concepts of “application,” “summary window,” and “un-launched state” which form the core of the claim are specific to devices like computers and cell phones. It further noted, even “if claims were directed to an abstract idea, it would still be patent eligible at least because it passes the machine-or-transformation test.”

The case proceeded for trial after denial of summary judgement. The district court found that a conundrum existed as to how the words “reached directly” and “un-launched state”, as mentioned in the claims of the disputed Patents,are mapped to the actual functionality. Hence, the court offered an opportunity to both the parties to argue constructions of these terms.

LG requested for a judgement as a matter of law claiming the defence that the plaintiff had insufficient evidence to support the case and to prove infringement. They argued that the correct construction of “un-launched state” means “not running” and that the “reached directly” limitation required user interaction with the main menu, and no reasonable jury could have found infringement under such constructions.

After hearing the explanation provided by experts of both the parties, the district court ruled that “un-launched state” signifies “not displayed” and “reached directly” signifies “reached without an intervening step.” The district court declined to revisit claim construction stating that noting LG did not preserve its claim construction arguments in the original motion itself.

LG again requested for judgment as a matter of law. This time the defence taken was of anticipation, which questioned the novelty of the patents. The district court denied LG’s this motion and concluded “LG failed to overcome the presumption of validity accorded to the ’476 and ’020 Patents by clear and convincing evidence.”

In the Court of Appeals for the Federal Circuit, the district court’s decision was affirmed providing the following explanation.

Decision of the Court:

Three factual questions regarding the patentability of the claims in dispute, question of anticipation and whether there was an infringement or not, were answered by the Court of Appeals for the Federal Circuit.

The court noted, “The asserted claims in this case are directed to an improved user interface for computing devices, not to the abstract idea of an index, as argued by LG on appeal. Although the generic idea of summarizing information certainly existed prior to the invention, these claims are directed to a particular manner of summarizing and presenting information in electronic devices. The Claim of the ’476 patent requires “an application summary that can be reached directly from the menu,” specifying a particular manner by which the summary window must be accessed. The claim further requires the application summary window list a limited set of data, “each of the data in the list being selectable to launch the respective application and enable the selected data to be seen within the respective application.” This claim limitation restrains the type of data that can be displayed in the summary window. Finally, the claim recites that the summary window “is displayed while the one or more applications are in an un-launched state,” a requirement that the device applications exist in a particular state. These limitations disclose a specific manner of displaying a limited set of information to the user, rather than using conventional user interface methods to display a generic index on a computer. The claims recite a specific improvement over prior systems, resulting in an improved user interface for electronic devices.” This answered the question of patentability under 35 U.S.C. § 101 and affirmed that the claims are not directed to an abstract idea and there is no need to proceed to the second step of the inquiry.

It was observed by the courts of appeals that the claimed invention provided flexibility that prior art processors did not possess, and removed the need to design a separate memory system for each type of processor. This answers the question of anticipation.

Now parties’ dispute boiled down to whether the status bar is part of the accused “home screen.” This is a fact question that the jury resolved in favour of Core Wireless, and substantial evidence supports the jury’s finding. In the LG user manual, the status bar is the first section of the view identified as the home screen which answers the question of infringement.

Thus, United States Court of Appeals for the Federal Circuit upheld the district court’s denial of summary judgment that the claims are ineligible under 35 U.S.C. § 101. It also affirmed the district court’s denial of judgment as a matter of law that the claims are anticipated by Blanchard and the claims are not infringed.

Author: Mr. Akash Kiran More, Intern at Khurana & Khurana, Advocates and IP Attorneys. In case of any queries please contact/write back to us at

Leave a Reply

Your email address will not be published.

12 + seventeen =


  • January 2023
  • December 2022
  • November 2022
  • October 2022
  • September 2022
  • August 2022
  • July 2022
  • June 2022
  • May 2022
  • April 2022
  • March 2022
  • February 2022
  • January 2022
  • December 2021
  • November 2021
  • October 2021
  • September 2021
  • August 2021
  • July 2021
  • June 2021
  • May 2021
  • April 2021
  • March 2021
  • February 2021
  • January 2021
  • December 2020
  • November 2020
  • October 2020
  • September 2020
  • August 2020
  • July 2020
  • June 2020
  • May 2020
  • April 2020
  • March 2020
  • February 2020
  • January 2020
  • December 2019
  • November 2019
  • October 2019
  • September 2019
  • August 2019
  • July 2019
  • June 2019
  • May 2019
  • April 2019
  • March 2019
  • February 2019
  • January 2019
  • December 2018
  • November 2018
  • October 2018
  • September 2018
  • August 2018
  • July 2018
  • June 2018
  • May 2018
  • April 2018
  • March 2018
  • February 2018
  • January 2018
  • December 2017
  • November 2017
  • October 2017
  • September 2017
  • August 2017
  • July 2017
  • June 2017
  • May 2017
  • April 2017
  • March 2017
  • February 2017
  • January 2017
  • December 2016
  • November 2016
  • October 2016
  • September 2016
  • August 2016
  • July 2016
  • June 2016
  • May 2016
  • April 2016
  • March 2016
  • February 2016
  • January 2016
  • December 2015
  • November 2015
  • October 2015
  • September 2015
  • August 2015
  • July 2015
  • June 2015
  • May 2015
  • April 2015
  • March 2015
  • February 2015
  • January 2015
  • December 2014
  • November 2014
  • October 2014
  • September 2014
  • August 2014
  • July 2014
  • June 2014
  • May 2014
  • April 2014
  • March 2014
  • February 2014
  • January 2014
  • December 2013
  • November 2013
  • October 2013
  • September 2013
  • August 2013
  • July 2013
  • June 2013
  • May 2013
  • April 2013
  • March 2013
  • February 2013
  • January 2013
  • December 2012
  • November 2012
  • September 2012
  • August 2012
  • July 2012
  • June 2012
  • May 2012
  • April 2012
  • March 2012
  • February 2012
  • January 2012
  • December 2011
  • November 2011
  • October 2011
  • September 2011
  • August 2011
  • July 2011
  • June 2011
  • May 2011
  • April 2011
  • March 2011
  • February 2011
  • January 2011
  • December 2010
  • September 2010
  • July 2010
  • June 2010
  • May 2010
  • April 2010