University of Florida Research Foundation, Inc. v. General Electric Co.
The University of Florida Research Foundation (UFRF) patent is titled “Managing Critical Care Physiologic Data Using Data Synthesis Technology.” In 2017, UFRF sued GE, alleging infringement. GE argued that the claims of the patent were directed to ineligible subject matter under 35 U.S.C. 101. The district court dismissed, applying the two-step framework described by the Supreme Court in its 2014 “Alice” decision to conclude that the claims are directed to an abstract idea and do not recite an inventive concept. The Federal Circuit affirmed, first rejecting UFRF’s argument that, as an arm of the State of Florida, it enjoyed sovereign immunity under the Eleventh Amendment. By bringing its claim of infringement, UFRF waived its sovereign immunity as to any relevant defenses. The patent seeks to automate “pen and paper methodologies” to conserve human resources and minimize errors, a quintessential “do it on a computer” patent. Such claims are directed to abstract ideas. The claimed “programmatic action involving said machine-independent data” can be performed using “[a]ny kind of computer system or other apparatus,” including a “general-purpose computer system.” The claims do no “more than simply instruct the practitioner to implement the abstract idea . . . on a generic computer.” View "University of Florida Research Foundation, Inc. v. General Electric Co." on Justia Law