A digital camera claimed at a high level of generality is not eligible as an abstract idea | Knobbe Martens
Before Newman, Prost and Taranto. Appeal of the United States District Court for the ND of California
Summary: A device claim stating a digital camera with conventional components is not patent-eligible because it is directed towards the abstract idea of using a digital camera to take two photos and enhance one image with the other image .
Yanbin Yu and Zhongxuan Zhang have filed a patent infringement action against Apple and Samsung, alleging infringement of digital camera claims. The district court allowed the defendants’ motion to dismiss, concluding that each claimed claim was ineligible under §101 as they were directed towards the abstract idea of taking two photos and enhancing each other and did not recite anything other than the conventional limitations.
The Federal Circuit upheld the rejection, noting that the idea and practice of using multiple images to highlight each other was well known and that the claim spelled out conventional camera components to a high degree of generality while evoking the basic functions of the components. The Federal Circuit also pointed out that the specification was consistent with this finding, as it identified a “great need for a generic solution that makes digital cameras capable of producing high resolution images without [high] Cost. ”Additionally, the Federal Circuit observed a mismatch between the scope of the claimed claims and more specific embodiments described in the specification, stating that“ the purpose of the claimed advance is the abstract idea and not the particular configuration discussed in the specification which allegedly departs from the prior art. The Federal Circuit also concluded that the claims did not include an inventive concept for the claimed configuration which added “sufficient substance to the abstract idea under -jacent improvement ”.
Justice Newman disagreed, arguing that a digital camera is a mechanical and electronic device of defined structure and mechanism, not an abstract idea.
Publisher: Paul Stewart