IP Law Daily, PATENT—Fed. Cir.: Computerized image correction patents were directed to abstract ideas, (Apr 30, 2025)

By Kevin M. Finson, J.D.

Patent claims directed at correcting images on a computer were invalid because they simply directed the use of generic computer components to perform longstanding human activities without any specific improvement to the technology.

Google successfully showed that four patents asserted against it were invalid for being directed at an abstract ideas of organizing, altering, and manipulating data, the U.S. Court of Appeals for the Federal Circuit has held. Each of the asserted patents claimed longstanding human activities of image correction and simply directed that they be performed on conventional computer components ((Longitude Licensing Ltd. v. Google LLC, No. 24-1202 (Fed. Cir. Apr. 30, 2025)).

Longitude Licensing Ltd. (Longitude) was the owner of U.S. Patents Nos. 7,668,365 (the ’365 patent), 8,355,574 (the ’574 patent), 7,454,056 (the ’056 patent), and 7,945,109 (the ’109 patent), each of which were directed to performing digital image correction techniques on a computer. Longitude brought suit for infringement against Google, LLC (Google) in the Northern District of California. Before the trial court, Google prevailed on a motion to dismiss on the theory that each of the four patents was invalid for being directed to an unpatentable abstract ideas of “improving image quality by adjusting various aspects of an image based on features of the main object in the image.” Longitude appealed.

Abstract idea. Longitude argued that the trial court erred in step one of the Alice test because it claimed an improved image processing technique. The Federal Circuit found that none of the claim language actually explained how the claimed technique worked; it simply directed that the existing process of adjusting image parameters by a human be performed on a computer using functional, results-oriented language. The court referred back to longstanding caselaw that basic data collection and manipulation, without more, is abstract. The court also rejected Longitude’s argument that the trial court erred by treating one of the claims of the ’365 patent, finding that each of the claims suffered from the same defects as far as patentability was concerned.

Inventive concept. On step two of the Alice test, the appellate court held that Longitude had failed to identify a factual dispute which could not be resolved at the motion to dismiss stage as to whether the patents claimed an inventive concept. Longitude’s proposed inventive concept was merely a rephrasing of the abstract idea the court had already found unpatentable.

The Federal Circuit affirmed the district court’s dismissal.

The Case is No. 24-1202.

Judge: Dyk, T.

Attorneys: Aaron Robert Fahrenkrog (Robins Kaplan LLP) for Longitude Licensing Ltd. Ginger Anders (Tolles & Olson LLP) for Google LLC.

Companies: Longitude Licensing Ltd.; Google LLC

Cases: Patent FedCirNews CaliforniaNews