Contour Ip Holding LLC v. Gopro, Inc.
Not yet published; slip opinion (2024)
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Rule of Law:
Patent claims are not directed to an abstract idea under 35 U.S.C. § 101 when they recite a specific technological means that improves the relevant technology, rather than merely claiming an abstract result or effect.
Facts:
- Contour IP Holding LLC ('Contour') owns patents for portable, point-of-view ('POV') action sports video cameras.
- At the time the patents were filed, users of POV cameras, such as skiers with helmet-mounted cameras, could not easily see what was being recorded or adjust camera settings during an activity.
- Contour's patented invention addresses this problem with a camera configured for remote image acquisition and control.
- The camera's processor is configured to generate two video streams from the image sensor data 'in parallel': a high-quality stream and a low-quality stream.
- The camera wirelessly sends the low-quality stream directly to a remote personal computing device, like a cell phone, for real-time previewing.
- This system allows the user to view what the camera sees on the remote device and send control signals back to the camera to adjust settings like alignment, lighting, and color, while the high-quality stream is saved on the camera itself.
- This dual-stream method solves the problem of wireless connection bandwidth limitations that would prevent streaming a high-quality video in real time.
Procedural Posture:
- Contour IP Holding LLC ('Contour') sued GoPro, Inc. ('GoPro') in the U.S. District Court for the Northern District of California for patent infringement.
- During the litigation, the district court construed the claim term 'generate' to mean 'record in parallel from the video image data.'
- GoPro filed a motion for summary judgment, arguing that Contour's asserted patent claims were invalid under 35 U.S.C. § 101 because they were directed to a patent-ineligible abstract idea.
- The district court granted GoPro's motion, finding the claims were directed to the abstract idea of 'creating and transmitting video (at two different resolutions) and adjusting the video’s settings remotely' and lacked an inventive concept.
- The district court entered a final judgment in favor of GoPro.
- Contour, as the appellant, appealed the district court's summary judgment decision to the U.S. Court of Appeals for the Federal Circuit.
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Issue:
Are patent claims for a point-of-view camera that simultaneously records two different quality video streams in parallel and wirelessly transmits the lower-quality stream to a remote device for real-time viewing and control directed to a patent-ineligible abstract idea under 35 U.S.C. § 101?
Opinions:
Majority - Reyna, Circuit Judge
No, the patent claims are not directed to a patent-ineligible abstract idea. The claims are directed to a specific technological means that improves the functionality of point-of-view cameras, not merely to the abstract idea of remote video control. The court reasoned that the focus of the claimed advance is a specific technological improvement: the camera's ability to record low- and high-quality data streams in parallel and wirelessly transfer only the low-quality stream to a remote device. This specific configuration solves the technological problem of bandwidth limitations on wireless data transfer, enabling real-time remote viewing and control. The court distinguished this from prior cases like Yu v. Apple, where the claims were directed to the long-known, fundamental practice of using one photo to enhance another. Here, the claims are not directed to an abstract result but to a specific 'how'—a particular implementation that improves the camera's operation. By characterizing the claims at a high level of abstraction, the district court erred and failed to recognize the specific technological solution recited in the claims.
Analysis:
This decision reinforces the principle that patent eligibility analysis under Alice step one requires a specific, non-abstracted view of the claims. It clarifies that a claim reciting a particular technological improvement to solve a technological problem is not 'directed to' an abstract idea, even if it involves known components like wireless transmitters and processors. The court's distinction of this case from precedents like Yu and ChargePoint signals that the 'focus of the claimed advance' should be evaluated based on the specific technical solution offered, not a generalized description of the outcome. This holding may provide a stronger basis for patentees to defend against § 101 challenges by emphasizing the specific technical improvements and solutions recited in their claims, pushing back against overly broad characterizations of their inventions as abstract.
