Framed as a Technological Improvement, Camera Patent Survives

In Contour IP Holding LLC v. GoPro, Inc., No. 22-1654 (Fed. Cir. Sep. 9, 2024), the Federal Circuit reversed summary judgment that Contour’s patent was ineligible under 35 U.S.C. § 101. At issue on appeal was whether the claims were directed to patent-ineligible subject matter.

The Federal Circuit began and ended its analysis at Alice step one, finding the claims were not directed to an abstract idea but were instead directed to an improved point of view (“POV”) camera.

The Federal Circuit disagreed with the district court’s “impermissibly high level of generality” in characterizing the claims. The Federal Circuit instead focused on the claimed POV camera’s specific technical means of operation—(1) parallel recording of multiple streams and (2) wirelessly transmitting a lower quality stream to a remote device—that provide an improvement to real time viewing of a POV camera recording on a remote device.

The Federal Circuit was unpersuaded by GoPro’s arguments that the claims were analogous to the ineligible claims in Yu v. Apple Inc., 1 F.4th 1040 (Fed. Cir. 2021) and ChargePoint, Inc. v. SemaConnect, Inc., 920 F.3d 759 (Fed. Cir. 2019). The Court distinguished these cases by finding the claims of Contour’s patent did not recite a longstanding, fundamental practice and that the specification described achieving improvements to POV camera technology through the specific means claimed.