ChargePoint, Inc. v. SemaConnect, Inc.
Antitrust Patent JusticiabilityDoctri
Whether a patent claim to a new and useful improvement to a machine or process may be patent eligible even when it 'involves' or incorporates an abstract idea
QUESTIONS PRESENTED Section 101 of the Patent Act provides that “[w]hoever invents or discovers any new and useful process, machine, manufacture, or composition of matter, or any new and useful improvement thereof, may obtain a patent therefor, subject to the conditions and requirements of this title.” This Court has long maintained an implicit exception to Section 101: “Laws of nature, natural phenomena, and abstract ideas are not patentable.” Alice Corp. Pty. Lid. v. CLS Bank Intl, 134 S. Ct. 2847, 2354 (2014). However, the Court has consistently held that incorporation of an abstract idea into an invention remains patent eligible. Diamond v. Diehr, 450 U.S. 175 (1981). The questions presented are: 1. Whether a patent claim to a new and useful improvement to a machine or process may be patent eligible even when it “involves” or incorporates an abstract idea. 2. Whether the Court should reevaluate the atextual exception to Section 101. (i)