In re McDonald., No. 2024-1015 (September 10, 2024) (nonprecedential); Patent Application No. 15/454,677

Key point(s):

• A claim that recites a method of organizing human activity, such as the fundamental economic practice of making commercial tipping payments, requires an improvement of the computer’s capabilities to overcome a patentable subject matter rejection.
• The rationale for combining the teachings of multiple references in an obviousness rejection may include a discussion of how the combination would not interfere with the functioning of the references, would be predictable, would have a reasonable expectation of success, or would improve the performance of the combined system.

Contour IP Holding LLC v. GoPro, Inc., Nos. 2022-1654, 2022-1691 (September 9, 2024) (precedential) (3–0); Patent Nos. 8,890,954 and 8,896,694

Key point(s):

• A claim that enables a wireless device (such as point-of-view (POV) camera) to ‘operate differently than it otherwise could’ within a wireless communication environment satisfies step one of an Alice inquiry for patent eligible subject matter.
• More particularly, an improvement in POV camera technology that generates both high-quality and low-quality video streams in parallel and wirelessly transfers the low-quality video stream to a remote device is patentable subject matter.