TLI Commc'ns LLC v. AV Auto., L.L.C., No. 15-1372 (Fed. Cir. 2016)
Annotate this CaseTLI filed suits, alleging that the defendants infringed its 295 patent by making, selling, and/or using products and services that allow uploading of digital photos from a mobile device, such as a cell phone. The 295 patent “relates generally to an apparatus for recording of a digital image, communicating the digital image from the recording device to a storage device, and to administering the digital image in the storage device.” The specification notes that a “wide variety of data types” can be transmitted, including audio and image stills. The Judicial Panel on Multidistrict Litigation consolidated the cases for pre-trial purposes in the Eastern District of Virginia. That court dismissed, concluding that the patent fails to claim patent-eligible subject matter under 35 U.S.C. 101, and that, in the alternative, certain claims are invalid for failing to recite sufficient structure as required by 35 U.S.C. 112. The Federal Circuit affirmed, holding that limiting the abstract idea of classifying and storing digital images in an organized manner to a particular environment—a mobile telephone system—does not make the claims any less abstract.
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