Bonum Certa Men Certa

Software Patents in the US and the European Loopholes Revisited

FRAND (in a standard) or "on a device" loophole

A device



Summary: While the United States distances itself from patent maximalism and moves further away from software patenting, the issue is still unresolved in Europe, which traditionally rejected such patent applications upfront

SOFTWARE patents are certainly a dying breed of patents in the United States, especially after Alice. Those who deny these trends are typically lobbyists of the software patents interest groups/profiteers. This report which was authored by Charles Bieneman, says that even the Court of Appeals for the Federal Circuit (CAFC), originator of software patents in the United States, walks back on the issue and "Maintains Unpredictability of the Law of Patent-Eligibility". To quote Bieneman: "The Federal Circuit vacated a summary judgment of invalidity under 35 U.S.C. €§ 101 after disagreeing with a district court that claims of U.S. Patent No. 7,604,929 were “directed to a patent-ineligible law of nature–that hepatocytes [liver cells] are capable of surviving multiple freeze-thaw cycles–and that the patented process lacks the requisite inventive concept.” Rapid Litigation Management, Ltd. V. Cellzdirect, Inc., No. 2015-1570 (Fed. Cir. July 5, 2016). Reading this case for broader lessons on Section 101 validity – as I read all cases that implement the Mayo/Alice patent-eligibility test – the main lesson to be drawn here is that outcomes under Section 101 remain highly situational. Patent-eligibility determinations, even more than other questions of patent law, frustratingly depend on the context of the litigation, specific words that may or may not be included in a patent claim, and, let’s be honest, the particular judge or judges hearing the case."



"The courts which actually count and are not known for corruption quite unequivocally reject software patents."At the CAFC, as noted here many times before, trial misconduct is common. It's a corrupt process. Consider the recent BASCOM case which is still mentioned in the news this week. SCOTUS, which bypasses CAFC, continues to reject challenges to Alice, e.g. the Sequenom case -- a subject which was also revisited earlier this week. The courts which actually count and are not known for corruption quite unequivocally reject software patents.

Europe, on the other hand, risks going in the very opposite direction.

According to last week's blog post from Cambridge Wireless Blog (based in the UK), "not all software is patentable, and never has been. But this is generally true: not everything is patentable. As straightforward examples, you cannot patent a piece of art, or a book, or a theme or story for a book, say. These are regarded as “non-technical”. Likewise, you cannot patent a pure business method, again in essence because they are regarded as “non-technical” and for policy reasons. You also cannot patent “scientific theories” or “mathematical methods”, again essentially for policy reasons: no-one should be allowed to patent what is already “out there”, waiting for humans to uncover it."

""fluffy" software is not patentable but "hard" software is," Benjamin Henrion noted about the premise of the above. "There is no such thing as hard software," he added. This is perhaps where the EPO loophole comes into play. If one pretends that the software is tied or combined with a device, then suddenly the software is deemed patentable. Another loophole for software patenting in Europe has been FRAND. We wrote about this for nearly a decade. FRAND has been a vector of software patents injection into standards, even where software patents are not at all valid. "FRAND And The Clash Of Industries," an article published earlier today, says the following:

They use open source licenses to handle the copyrights and patents, community governance to handle trademarks and other patents and public benefit entities to protect everyone from everyone else. Each participant in the collaboration works at their own expense in order to achieve a shared outcome that benefits all, including themselves. When they create an enhancement, fix a defect, participate in a design, they are not “working for free” or “donating their work” so much as they are “participating in co-development”. It’s a new way to leverage IP for greater benefit than directly monetising its scarcity.

[...]

But that’s not the case in markets where collaboration happens at the level of specifications and de jure standards rather than code and de facto standards, such as the telecommunications industry. Decades of comfort with SEPs and FRAND terms have resulted in a heavy investment in patents licensed in such a way that they create mutually-assured control. Telecommunications standards are so heavily encumbered with SEPs that patent pools and cross-licensing have become the norm. That in turn has created a barrier to newcomers that has made the telecommunications industry a cartel of giants.

That cartel of giants now sees its mesh of complex physical technologies coming to a lifecycle point where software dominates. The rise of apps and smart devices for the user and of software-defined and implemented infrastructure for operators, means that there is more and more of an incentive to move in to the computer and software technology markets. This in turn has created an impetus to adopt the working practices of that industry, which notably today means collaboration over shared implementation rather than just over mutually essential specifications. As a result, they seek to introduce open source into their business.

[...]

So will we create a new opportunity with regulations like EIF, or allow an existing industry to hobble another as the two collide? That’s the real question about FRAND terms for SEPs. Trying to force-fit FRAND into open source by mistakenly asserting it’s just a matter of compliance is sure to fail. Despite the name, FRAND is always discriminatory.


It is sad that so many years down the line, nearly a decade after Microsoft lobbied via groups like the Business Software Alliance, this subject remains unaddressed and FRAND remains a big barrier, even in Europe. There is much work to be done in Europe, even if the US gradually ends the era of software patenting.

Recent Techrights' Posts

Links 31/07/2026: Microsoft Now Says Slop is Bad (LinkedIn Cracks Down on It), LinkedIn Narrows Down Size (No Expansion)
Links for the day
European Patent Office (EPO) Series: From Alicante to Munich: Another Smooth Ride
Campinos is intent on transforming what was originally envisaged as a temporary public office into his own permanent personal feather-bed
Daniel Pocock and the Important Observation About Threats of Cult-Like Behaviours (No Rationality, No Reason, Just "Mob Rule")
It's a threat to Europe's sovereignty
The "PIP Parade" of IBM's Lousy Management, Which Said "Blockchain" Was the Future
In a healthy company such a CEO would be punished for utterly wrong visions and predictions. Not at IBM...
SLAPP Censorship - Part 135 Out of 200: Limited Liability Partnership (LLP) That Does Not Disclose Financial Activities Before August
It certainly looks like they keep losing the remaining women that still exist in the firm
Links 31/07/2026: "Climate Cover-Up Continues" and Pesticides "Cook the Planet"
Links for the day
Datacentre 'Boom' Sceptics Aren't Luddites, They Recognise a Threat to Human Survival (Not Limited to Climate Change)
Archaeologists very well know that no species will survive forever
Microsoft's Claims Are Based on a Big Lie
the bubble is coming to its hard limits
Don't Lose Sight of the Impact of "End of 10" (Vista 10)
GNU/Linux has taken off fast
Microsoft's Debt Continues to Steadily Increase, Not Counting Hundreds of Billions in Secret/Hidden Debt
The mass layoffs will carry on, maybe labelled LITE
IBM is Circling Down the Drain, the 'Growth' Comes From Beancounting Tricks and Salary Cuts
IBM was down 2.17% yesterday
Microsoft's "Headcount" Distracts From How Big a Cull It Had This Month
It also speaks of numbers "[a]s of June 30" though the "buyouts" were effective July 1 and since then well over 10,000 workers have vanished
Over at Tux Machines...
GNU/Linux news for the past day
IRC Proceedings: Thursday, July 30, 2026
IRC logs for Thursday, July 30, 2026
Gemini Links 31/07/2026: Music, Journaling, and Longing
Links for the day
More Fake News From (and for) IBM, Nobody Ever Held Accountable for Fraud
Companies that turn a blind eye to their own corruption end up recruiting more corrupt people and sacking those who object to the corruption
Links 30/07/2026: Smol Document Server and More PalmOS-ing
Links for the day
Links 30/07/2026: Microsoft Refuting Its Own Slop Hype and "Amazon Is Gutting Its Hey Hi (AI) Division" (GAFAM Bubble)
Links for the day
Today The Register MS Published "AI" Spam and Fake Article by "Senior Technical Marketing Engineer"
unethical practices
Cult inquiry parliament leak fallout
Reprinted with permission from Daniel Pocock
Techrights Will Always Protect Sources
Our #1 priority is sources
European Patent Office (EPO) Series: Legal Concerns and Suspicions of Irregularities
complaints submitted to OLAF
The Era of Silence
So stay silent, remain hidden
GAFAM and IBM Dying in Massive Debt, Hence the Mass Layoffs (Increasingly Silent Layoffs That the Media Fails to Mention)
the integrity of this economy is only as good as its leaders or those who govern the market
TheLayoff.com Deletes Comment That Called IBM's Previous CEO, Ginni Rometty, "Gin 'n Tonic"
It is hard to believe the comment was deleted for being a duplicate (in another thread)
The Mainstream Media Continues to Overlook or Intentionally Ignore Hundreds of Billions in Hidden/Secret Microsoft Debt
the issue is that Microsoft's crisis is a lot greater and broader than this
SLAPP Censorship - Part 134 Out of 200: What "Majority Rules" Tell Us About the Litigant
we press on with this series
Overshoot Day Sites That Contribute to the Problem
Some of these are not even accessible (at all) without JavaScript
Microsoft May Have Gotten Rid of 8% of Its Workforce This Month
It's hard to know what's really going on because there's no transparency due to NDAs
Links 30/07/2026: "Age of Irrationality", Google Losing Money, and "House of Ellison is on the Brink"
Links for the day
Gemini Links 30/07/2026: Homeworlds Notes and Manuscript Submitted
Links for the day
Over at Tux Machines...
GNU/Linux news for the past day
IRC Proceedings: Wednesday, July 29, 2026
IRC logs for Wednesday, July 29, 2026
As Expected, Facebook Collapses, Microsoft Hides Massive Debt
GAFAM is a giant mountain of debt
At The Register MS "PARTNER CONTENT" Means Company Writing Fake Articles About Itself and Its Own Products
At The Register MS, content-farming has become a thing
Staff of EPO Cautions Against Unlawful Weaponisation of PIPs Against Industrial Actions That Protest Corruption
PIP-like sanctions against anybody who does not toe the line of Cocaine King?
IBM, Running Out of Things It Can Sell, is Selling Software Patents
IBM is not just pathetic; it's actively harmful because it lobbies for software patents and spreads software patents around
Gemini Links 29/07/2026: Star Trek, Retirement, and ODEs in GNU Octave
Links for the day
Links 29/07/2026: "BuzzFeed Lays Off 33 Percent of Remaining Staff" (Trying LLM Slop Some More), Scam Altman Mocked by the Media
Links for the day
GNOME Curated and Censored by IBM (Under the Guise of "Code of Conduct")
Felipe Borges (IBM) has just posted a follow-up
Digital Mass Surveillance as a Hallmark of Failed Societies
"small leap forward in tech ethics"
I Found a Typo, Don't Vote!
Social control media isn't good at adding any meaningful signal
Jeremy Sands Explained the Harms of Codes of Conduct
next week the 500th show milestone [is reached]
Tonight's Earnings Report From Microsoft and Facebook ('Meta') Will be Faked Because They Hide Almost a Trillion Dollars in Debt
The US economic system is only as honest as the people who govern it
The Vacuum Syndrome
Parables help
The Only Old People Who Can Survive IBM Are the CEO and His Circle of Enablers
very similar to what's happening at the EPO
The 'Church' of Moglen/Stallman
'reunion' with Eben Moglen
Microsoft Layoffs Aren't Done Ahead of the Need to Tell Shareholders About "Efficiency" (Tonight)
Microsoft layoffs won't be "Done" until what's left of Microsoft is "None"
Microsoft Lacks Growth. Ahead of 'Results' The UK's Competition and Markets Authority (CMA) Finds Merit in Allegations Slop is Microsoft's Excuse for Price Hikes (Piggybacking Vendor Lock-in).
At this stage it's not hard to see why many nations gravitate away from Microsoft
Parliament leaks confidential cult inquiry witness contact list (COFG Victoria)
Reprinted with permission from Daniel Pocock
Troll-Feeding is Time-Wasting
in social control media
WordPress is Technical Debt
There are a number of technical tasks underway and maybe some testing (this coming weekend or later)
Will Red Hat Still Exist in 2027 or Just Become a "Brand" at IBM?
Whistleblowers told us IBM was laying off about 500 Red Hat engineers earlier this year
Call for IBM Whistleblowers
If you work for IBM and have something material (like balance sheets) to prove financial misconduct, please try to 'touch base' and establish a secure communication channel we can both use
EPO Series on EU and Pan-European Corruption, Vote-Rigging, Extending Beyond the EPO Itself
By Saturday it will be August already, so we'll start preparing for Rianne's birthday
SLAPP Censorship - Part 133 Out of 200: Lies by Omission
As usual, the other side wants people to ignore how much they lost
European Patent Office (EPO) Series: Streamlining the Decision-Making Process
Negrão was one of 17 applicants for the position but he somehow managed to end up as the sole candidate on the shortlist prepared by the Management Board in June 2020
Links 29/07/2026: "Hugging Face Has a Deepfake Nudes Problem" and "$1.5B Anthropic Copyright Infringement Ruling" (Plagiarism is Not "Training")
Links for the day
Comments on Today's Judgment
It hopefully helps clarify what actually happened
Microsoft Has Fallen to #3 in Singapore
There are many technically talented people in Singapore or overseas workers who lodge in Singapore
Thank You, Andy
Burnham and "Tech Rights"
Solicitors Regulation Authority (SRA) Inaction and Incompetence - Part II - 77 Messages Sent, Did Not Even Investigate or Examine Any of the Actual Evidence (British Taxpayers' Money Wasted)
SRA has become known (even notorious) for inaction
Inevitable Politics
In technology, provided the work you do has growing impact (we served almost 2 million requests yesterday), things will inevitably become more political - whether you like it or not does not matter
Not Only "Loonies Take on Farage"
pretending that the opposition to the right wing is "Loonies"
Brigading Against Women - Part I - Bypassing the Legal System by Threatening Companies in Another Continent
In the next part we'll begin to connect Lozza's online activities (and court activities) to those of Garrett
IBM is Trying to Turn Debt (Borrowed Money) Into Fake Growth and It'll Worsen Matters
they put in their balance sheets a fake "growth" in something that does not even exist
Microsoft Relies on Misleading Narrative of Studios Going 'Independent'; in Reality There Are Mass Layoffs in Them
This is not a good narrative for Microsoft
Over at Tux Machines...
GNU/Linux news for the past day
IRC Proceedings: Tuesday, July 28, 2026
IRC logs for Tuesday, July 28, 2026
Gemini Links 29/07/2026: Arosa, Tired Tuesday, and Constellation Browser
Links for the day