A Digital Camera Claimed At A High Level Of Generality Is Ineligible As An Abstract Idea

| Serah Friedman, Ph.D.


Before Newman, Prost, and Taranto.  Appeal from the U. S. District Court for the N.D. California

Summary: An apparatus claim reciting a digital camera with conventional components is patent ineligible as directed to the abstract idea of using a digital camera to take two pictures and enhance one picture with the other picture.

Yanbin Yu and Zhongxuan Zhang filed a patent infringement suit against Apple and Samsung alleging infringement of claims concerning a digital camera.  The District Court granted the defendants’ motion to dismiss, concluding that each asserted claim was patent ineligible under §101 because they were directed to the abstract idea of taking two pictures and enhancing one with the other and failed to recite anything other than conventional limitations. 

The Federal Circuit affirmed the dismissal, noting that the idea and practice of using multiple pictures to enhance each other was well known and that the claim recited conventional camera components at a high degree of generality while reciting basic component functions.  The Federal Circuit also pointed to the specification as being consistent with this conclusion, for it identified a “great need for a generic solution that makes digital cameras capable of producing high resolution images without [high] cost.” Additionally, the Federal Circuit observed a mismatch between the breadth of the asserted claims and more specific embodiments described in the specification, stating that “the focus of the claimed advance is the abstract idea and not the particular configuration discussed in the specification that allegedly departs from the prior art.”  The Federal Circuit also concluded that the claims did not include an inventive concept for the claimed configuration that added “sufficient substance to the underlying abstract idea of enhancement.”

Judge Newman dissented, arguing that a digital camera is a mechanical and electronic device of defined structure and mechanism and not an abstract idea. 

Editor: Paul Stewart