Fed. Cir. Voids 'Result-Oriented' Claims, OKs Per-Limitation Standards Proof

The U.S. Court of Appeals for the Federal Circuit issued a split ruling on patent eligibility and clarified the use of industry standards as proof of infringement. In Constellation Designs v. LG Electronics, the court found that patent claims directed broadly to optimizing a signal constellation for a particular result were patent-ineligible abstract ideas under 35 U.S.C. § 101. However, claims reciting specific, concrete constellation structures were deemed eligible as they represented a tangible technological improvement. The court also addressed a key issue in infringement litigation, holding that a plaintiff can rely on an industry standard to prove that an accused product meets specific claim limitations, even if the standard does not cover every limitation of the claim. This endorses a 'limitation-by-limitation' approach, clarifying precedent from Fujitsu v. Netgear. The decision provides a more efficient path for patentees to prove infringement in complex technology sectors where standards are prevalent. For patent prosecutors, it underscores the importance of drafting claims that recite specific implementations, not just desired outcomes. The court also affirmed the district court's damages rulings.