3 opinions in the patent, trademark, design patent, and trade dress categories. Rule 36 affirmances and non-IP dispositions excluded.
In Flip Phone Games, Inc. v. PLR Worldwide Sales Ltd., the Federal Circuit dismissed three consolidated appeals (Nos. 2025-2053, 2025-2054, and 2025-2057) from Patent Trial and Appeal Board decisions in IPR2024-00132, IPR2024-00171, and IPR2024-00200 pursuant to a joint stipulation under Federal Rule of Appellate Procedure 42(b). The court ordered that each side bear its own costs.
Panel: Dyk, Hughes, Stoll
The Federal Circuit affirmed the district court's judgment in consolidated actions between J.R. Simplot Co. and McCain Foods USA, Inc. (and related parties) concerning U.S. Patent No. 6,821,540. The court held claims 1 and 6 invalid as indefinite under 35 U.S.C. § 112.
The court issued a per curiam opinion disposing of the appeal solely on indefiniteness grounds without substantive analysis in the published text. This procedural posture—affirming invalidity under § 112 at the appellate level after what appears to have been district court claim construction and validity determinations—suggests the parties' disputes over claim scope proved fatal to enforceability. The brevity of the disposition and the consolidation of multiple related cases indicate the indefiniteness finding resolved all pending disputes between the parties without need to reach infringement or other validity challenges.
Panel: Reyna, Stoll, Cunningham
The Federal Circuit affirmed the Western District of Wisconsin's grant of summary judgment that all asserted claims of six patents owned by Innovaport LLC—U.S. Patent Nos. 8,775,260, 8,787,933, 9,489,690, 9,990,670, 7,231,380, and 7,819,315—are invalid under 35 U.S.C. § 101 in Target Corporation's favor. The patents claim systems and methods for providing product location information within stores, including receiving customer inquiries, querying databases containing product location and related information (such as pricing, inventory, and cross-referenced products), and providing suggestions based on customer preferences and past inquiries. Innovaport argued the district court erred in selecting claim 15 of the '260 patent as representative and in finding the claims abstract at Alice/Mayo step one and lacking an inventive concept at step two.
The court declined to address representativeness, holding that even if the differences among claims were material, each would independently fail § 101. At step one, the court determined the claims are directed to the abstract idea of collecting, analyzing, retrieving, and displaying information—functions that could be performed by a human store clerk using pen and paper or mental processes. The court rejected Innovaport's argument that linking related products in a database and providing customer suggestions constituted a technical improvement, reasoning that improving user experience without more does not render claims directed to an improvement in computer functionality, and that the specification described solving a business problem using generic computing components rather than advancing computer technology itself.