Berkheimer v. HP Inc.

881 F.3d 1360 (2018)

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Berkheimer v. HP Inc.

United States Court of Appeals for the Federal Circuit
881 F.3d 1360 (2018)

Facts

Steven Berkheimer (plaintiff) held a patent regarding a digital-asset-management system that digitally processed and archived files. Specifically, claim 1 described a method of archiving that involved analyzing data and comparing it to previously stored data, then presenting the data to the user for reconciliation if a variance was detected between the new data and archived data. Claim 4 described parsing, comparing, and storing data in a way that reduced redundancy in the archive and thus increased efficiency and reduced storage costs. Claims 5 to 7 described parsing, comparing, storing, and editing data using an editing process that took edits made to an object and applied them to that object anywhere it appeared in the archive, thus providing a one-to-many editing feature. Berkheimer sued HP Inc. (defendant), alleging that HP was infringing Berkheimer’s patent. HP moved for summary judgment, arguing, among other things, that claims 1 to 7 were ineligible for patent protection under 35 U.S.C. § 101. The district court granted summary judgment in HP’s favor. Berkheimer appealed.

Rule of Law

Issue

Holding and Reasoning (Moore, J.)

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