For the 937 and 023 patents specifically, Veeva argues that the claims offer technical improvements in the field of electronic communications. Id. at 13-16 (analogizing to Core Wireless Licensing S.A.R.L. v. LG Elecs., Inc., 880 F.3d 1356 (Fed. Cir. 2018)). For the 313 patent, Veeva adds that the claimed method solves a technical problem arising from CRM interfaces with a specific programming approach.
The Fifth Circuit views all evidence in a light most favorable to the verdict and will reverse a jury's verdict only if the evidence points so overwhelmingly in favor of one party that reasonable jurors could not arrive at any contrary conclusion.” Core Wireless Licensing S.A.R.L. v. LG Elecs., Inc., 880 F.3d 1356, 1361 (Fed. Cir. 2018) (citing Bagby Elevator Co. v. Schindler Elevator Corp., 609 F.3d 768, 773 (5th Cir. 2010)).
Thus, the Court need not reach Alice step two. SeeCore Wireless Licensing S.A.R.L. v. LG Elecs., Inc. , 880 F.3d 1356, 1363 (Fed. Cir. 2018) ("Because we hold that the asserted claims are not directed to an abstract idea, we do not proceed to the second step of the inquiry."). B. The ’100 Patent
"The Fifth Circuit views all evidence in a light most favorable to the verdict and will reverse a jury's verdict only if the evidence points so overwhelmingly in favor of one party that reasonable jurors could not arrive at any contrary conclusion." Core Wireless Licensing S.A.R.L. v. LG Elecs., Inc. , 880 F.3d 1356, 1361 (Fed. Cir. 2018) (citing Bagby Elevator Co. v. Schindler Elevator Corp. , 609 F.3d 768, 773 (5th Cir. 2010) ). A court must "resolve all conflicting evidence in favor of [the verdict] and refrain from weighing the evidence or making credibility determinations."
Our law demands more."). IBM argues that its claimed invention is like one we held patentable in Core Wireless Licensing S.A.R.L. v. LG Electronics, Inc. , 880 F.3d 1356 (Fed. Cir. 2018), because it is "directed to particular or specific implementations of presenting information in electronic devices." Appellant's Br. 58 (citing Core Wireless , 880 F.3d at 1362–63 ).
If the claims are not directed to a patent-ineligible concept under Alice step 1, "the claims satisfy § 101 and we need not proceed to the second step." Core Wireless Licensing S.A.R.L. v. LG Elecs., Inc. , 880 F.3d 1356, 1361 (Fed. Cir. 2018) (citing Visual Memory LLC v. NVIDIA Corp. , 867 F.3d 1253, 1262 (Fed. Cir. 2017) ). If the claims are directed to a patent-ineligible concept, however, we next consider Alice step two.
GPN points to various Federal Circuit cases that it contends found similar claims eligible at Alice step one. See D.I. 21 at 11-13 (citing Core Wireless Licensingv. LGElecs., 880 F.3d 1356 (Fed. Cir. 2018) and McRO, Inc v. Bandai Namco Games Am. Inc., 837 F.3d 1299 (Fed. Cir. 2016)); D.I. 26 (letter citing these as the most on-point step one cases).
Alice, 573 U.S. at 217. If the claims are not directed to a patent-ineligible concept, “the claims satisfy § 101 and [the Court] need not proceed to the second step.” Core Wireless Licensing S.A.R.L. v. LG Elecs., Inc., 880 F.3d 1356, 1361 (Fed. Cir. 2018). If, however, the Court finds that the claims at issue are directed to a patent-ineligible concept, the Court must then, at step two, search for an “inventive concept” - i.e., “an element or combination of elements that is ‘sufficient to ensure that the patent in practice amounts to significantly more than a patent upon the [ineligible concept] itself.'”
The Asserted Claims are instead directed to an improved user interface for computer devices allowing for more efficient programming of microcontrollers. See Core Wireless Licensing S.A.R.L. v. LG Elecs., Inc., 880 F.3d 1356, 1362 (Fed. Cir. 2018) (“The asserted claims in this case are directed to an improved user interface for computing devices, not to the abstract idea of an index[.]”); (see also D.I. 20 at 13-16)
In Core Wireless Licensing S.A.R.L. v. LG Elecs. Inc., 880 F.3d 1356 (Fed. Cir. 2018), the Court considered the patentability of two patents that "disclose[d] improved display interfaces, particularly for electronic devices with small screens like mobile telephones." 880 F.3d at 1359.