In Polar Electro Oy v. Suunto Oy, No. 24-1801 (Fed. Cir. Dec. 3, 2025), the Federal Circuit summarily affirmed, under Rule 36, a district court judgment holding U.S. Patent No. 6,537,227 (the ’227 patent) invalid as directed to patent-ineligible subject matter. The ’227 patent is directed to a wearable heart-rate monitor and an associated method for assessing energy expenditure during physical exercise. The district court applied the two-step Alice framework. At step one, the district court determined that the claims were directed to an abstract idea related to mental processes, reasoning that its recited steps of measuring, obtaining, and assessing amounted to no more than gathering information and performing a calculation that did not require a computer. At step two, the district court found no inventive concept, rejecting as insufficient an expert declaration that the claims employed an “oddball” approach by working backward from VO₂max without regard to the source of that value. The district court was not persuaded that the unconventional ordering of steps in the claims supplied the inventive concept needed to transform the abstract idea into patent-eligible subject matter. Because the subject matter eligibility ruling was dispositive, the district court declined to reach the remaining invalidity and infringement issues. The Federal Circuit affirmed under Rule 36 without issuing a written opinion, despite arguments that the district court had impermissibly assembled an invalidity case not adequately supported with evidence.
Author: Lucas Stelling
Edited by Craig Drachtman