Grüneberg and Myers - Intellectual Property Law


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Patents for Networked Electric Vehicle Charging Station, Grounded

In Chargepoint v. Semaconnect the Fed. Cir. affirmed the D.Ct’s decision that claims to a networked charging station which allowed for management from a central location, for drivers to locate stations and to allow users to interact intelligently with the electricity grid were patent ineligible as directed merely to an abstract idea.  In analyzing Alice step 1, the Fed. Cir. relied on the specification to identify the focus of the invention and address the concern of pre-emption.  Notwithstanding that the plain language involved an abstract idea, the specification suggested that the claim was directed to the abstract idea of communication over a network to interact with a device connected to the network.  In spite of the increased functionality of a networked charging station, the Fed. Cir. found the concept of networking to be pre-empted, in the absence of any enabling technology for networking.  In Alice step 2, the Fed. Cir. found no additional feature sufficient to ensure that the patent in practice amounted to significantly more than a patent to an abstract idea.  Same result if claims are directed to a network of charging stations?  At least you would avoid the analysis of the charging station itself being improved or operating differently, and the system itself would operate differently because a networked system did not yet exist.

IPRichard Chinn