Federal Circuit Holds that Generic Hardware, Without Inventive Concept, Configured to Perform a Well-known Idea and Practice, Does Not Make a Claim Patent Eligible

The Federal Circuit, in Yu v. Apple Inc., Case No. 20-1760 (Fed. Cir. 2021), raised the bar on patent eligibility ruling that an abstract idea performed by a known mechanical/electronic device is patent ineligible under Section 101. The Court expressly limited eligibility analysis to the claim limitations, and refused to consider the specification for the purposes of claim eligibility. According to the Court, statements in the specification limiting novelty to particular embodiments can be used to show that broader claim language lacks inventive concept.

A link to the decision is here: http://www.cafc.uscourts.gov/sites/default/files/opinions-orders/20-1760.OPINION.6-11-2021_1789244.pdf