Access Denied: Patent for Controlling Entry Found Ineligible Under Section 101

Earlier this month in Luxer Corp. v. Package Concierge, the U.S. District Court for the District of Delaware found that U.S. Patent No. 11,625,675 was ineligible under Section 101. In assessing the defendant's motion to dismiss, the court determined that the claimed invention was "generally directed to a system and method for controlling electronic locks for locking a door of a storage room that is part of a building" – an abstract idea – and did not contain an inventive concept.

The patent specification describes a lock interface that determines "whether the credentials of a person attempting to access a package storage room are authentic" and, if authentic, "a signal is sent to an electronic lock to allow access to the package storage room."

We discuss the court's analysis below.

The Representative Claim

The defendant challenged whether claim one should be treated as representative. Though the patent challenger bears the initial burden of making a prima facie showing that the group of claims are substantially similar, the court noted that the burden then shifts to the patent owner to demonstrate why the eligibility of the purported representative claim is not decisive for the other relevant claims.

Here, the court found that the defendant made its prima facie showing, and the patent owner failed to provide any nonfrivolous reasons against treating the claims the similarly. The patent owner argued that other claims required "a power source," "a receiver that receives wireless signals," and "one or more capacitors that filter the signals …," but the court found that "merely providing examples of physical components does not demonstrate why those claims are not 'substantially similar.'" The court considered claim one as representative.

Alice Step One

The defendant argued that the claims "are directed to an abstract idea of authorizing access to a secure location upon verification of a user's credentials." This, the defendant asserted, mirrored the steps taken by a building's concierge in receiving and securing a delivered package – "receive a request to unlock a door; authenticate the user seeking access; approve the request upon authentication; and cause the lock to unlock or indicate that the user failed authentication."

As further support, the defendant directed the court to Fig. 5:

The plaintiff contended that the record does not suggest concierges ever controlled access to storage rooms using signals or codes to authenticate credentials – or ever employed electronic locks with the circuitry claimed by the patent. The court disagreed: "there is no question that humans are capable and routinely perform the task of securing areas and verifying credentials … That claim one performs the task with computer equipment and signals does not alter the nature of the task performed …"

The plaintiff further argued that the claim describes a machine and is, therefore, patent-eligible. The court agreed that the claim describes a machine but "qualifying as a machine is not dispositive of whether a technology is patent-eligible," citing Alice.

Finally, the plaintiff argued that the asserted claim is directed to "resolving the problem of a delivery person being unable to deliver a package because the door to the locker of the recipient will not open, because the locker is in use, the package is oversized, and there is no other locker available."

The court, again, disagreed: "a holistic reading of claim one … does not support that the focus of the claim is on improving access to package storage areas regardless of whether a storage area associated with the door is in use …" and found the representative claim to be directed to an abstract concept.

Alice Step Two

The court found that the "language of the patent supports that several of the listed components are well-understood and used in conventional ways," specifically pointing to the specification's discussion of known electronic locks.

The plaintiff countered that even if the individual components were generic, the defendant did not show the claimed combination was conventional. The court rejected this argument: "the components are organized in a logical fashion … The organization in claim one does nothing more than place the abstract idea of controlling access based on the verification of credentials into a technological environment."

The court determined that the representative claim was not patent-eligible under Section 101.

Representative Claim One

1. A system comprising:

at least one electronic lock for locking a door of a storage room that is stationary and part of a building, the storage room being large enough to accommodate packages that are small, medium, and oversized;

a lock interface that is communicatively coupled to the at least one electronic lock, the lock interface having at least one processor that implements one or more machine instructions stored on at least one non-transitory computer readable medium;

wherein the one or more machine instructions, when implemented, cause the processor of the lock interface to implement a method including at least

receiving, at the lock interface from a terminal, a first signal associated with a delivery, requesting access by unlocking the door;

in response, sending from the lock interface to the at least one electronic lock, a second signal including at least a request to open the door;

opening the electronic lock, based on the request, and allowing the access through the door, regardless of whether a storage area associated with the door is in use and regardless of whether the package is small, medium, or oversized;

wherein the request includes at least a user identity and a code, wherein the method further includes, after receiving the first signal including the request,

verifying, by the lock interface, the request by authenticating the user identity and the code received from the terminal;

approving the request, by the lock interface, after the user identity and the code are successfully authenticated;

in response to the approving of the request, sending the second signal, from the lock interface to the at least one electronic lock, the second signal causing the at least one electronic lock to automatically unlock, the at least one electronic lock including a circuit that includes at least

a signal input port that is communicatively connected to at least one signal output port of the lock interface;

an electronic switch that, in response to the receiving of signals from the lock interface, causes electric current to flow through the at least one electronic lock;

the step of verifying, by the lock interface, the request further including at least

comparing, by the lock interface, the user identity and the code received from the terminal with data stored in the lock interface;

approving the request, by the lock interface, when the user identity and the code received match the data stored in the lock interface, and

rejecting the request, by the lock interface, when at least one of the user identity and the code received does not match the data stored in the lock interface; and

in response to the rejecting of the request, sending, from the lock interface to the terminal, a message indicating that the request is invalid.

As always, thank you for reading.