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Federal Circuit Invalidates Garage Door Opener Patent Because It Is An Abstract Idea | Weintraub Tobin

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    Have you ever driven away from your home and then had that irritating doubt in your mind as to whether you remembered to close your garage door? I know I have. No matter how hard I try to search my brain’s archives, I really don’t remember whether I closed the garage door even though I close it 99.9% of the time! In that moment, you wish there was a way to check that doesn’t require turning around and going back home to see if you really left the house wide open for anyone to walk in.

    Well The Chamberlain Group, Inc. (“Chamberlain”) thought it had patented an invention that could help with this type of problem—a garage door opener that wirelessly transmits information such as whether the door is open or closed. See U.S. Patent No. 7,224,275 (the “’275 Patent”). Specifically, the patent “relates to an apparatus and method for communicating information about the status of a movable barrier, for example, a garage door.”

    Chamberlain sued Techtronics Industries Co. and others for infringing the ‘275 patent. See The Chamberlain Group, Inc. v. Techtronic Industries Co., et al. The jury found the patent was enforceable and had been willfully infringed. The district judge denied judgment as a matter of law for defendants determining that the claims were not directed to “the abstract idea of wireless transmission of content” but instead “to garage door openers that wirelessly transmit status information” and to “a particular improvement over…

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