Bonum Certa Men Certa

Half a Year Later the Patent Microcosm is Still 'Pulling a Berkheimer' in Vain

Citing a decision from way back (in February)

Pulling a Berkheimer



Summary: Earth-shattering changes are being insinuated by people who are in the business of 'selling' services around patents, never mind if 35 U.S.C. €§ 101 remains unchanged and Federal Circuit caselaw suggests likewise

LAST week in Patent Docs, a site of patent maximalists, Michael Hinrichsen, Anthony D. Sabatelli, and Jonathan Schuchardt (from some law firm) were trying to 'pull a Berkheimer' (and Aatrix). It's incredible that they're still trying to use these tricks about a third of a year down the line. Berkheimer and Aatrix have not changed anything profoundly; they're just being mentioned a lot by law firms in articles. They keep name-dropping Berkheimer and Aatrix, alluding to some vague need to assess underlying facts (as if courts didn't already assess facts). The new USPTO Director played along for a while, but he has since then taken a low-profile approach (like António Campinos at the EPO) and we assume that any changes associated with Berkheimer and Aatrix are 'fossilised'. Many law firms submitted comments, but nothing has actually changed.



The Patent Docs piece is more of the same, striving to or trying to add barriers to law (e.g. Section 101) being applied. The anti-Alice lobby isn't interested in justice or in patent scope; it's just trying to actively undermine SCOTUS. From the article:

Buried amidst the flurry of recent Federal Circuit subject matter eligibility decisions is a question that could significantly change how Section 101 is applied in patent litigation. Specifically, the issue is whether performing Step 2 of the Mayo/Alice test can require a factual inquiry. If upheld, this interpretation of Alice could make patent litigation much more complicated and expensive. In fact, Section 101 inquiries could become convoluted mini-trials in their own right -- similar to how Markman hearings are performed today.

[...]

Troubling questions continue to emanate from the factual vs legal question debate. Will other panels support this view of Step 2 of Alice? To date, all supporting decisions have been penned by Judge Moore. Additionally, HP has filed a petition for an en banc review. If upheld, it is unclear what level of evidence would be required for a court to conclude that a factual inquiry is necessary. Based on Berkheimer, it appears that if a specification describes a claimed feature as novel and that feature is eligible for consideration as an inventive concept, this may suffice to establish a genuine issue of material fact. It is unclear how such a factual inquiry would proceed, however, or what kind of evidence and how much of it would be required to establish that a claimed element is 'inventive.' Regardless of how these inquiries are eventually performed, if upheld, treating Step 2 of Alice as a legal question with factual underpinnings will undoubtedly complicate Section 101 inquiries.


Section 101 inquiries have been fine since and it's odd that they say a couple of old decisions "could significantly change how Section 101 is applied in patent litigation."

"Their logic is fairly simple: more patents = good, fewer patents = bad."It has barely changed a thing! It has been a long time since then, nearly half a year!

Patent Docs being Patent Docs (having also just advertised for patent maximalists [1, 2, 3, 4]), we don't suppose that it will even pen a piece about why Section 101 is good and software patents are bad. The site is run by patent law firms, whose sole goal is increasing their profits. The same goes for Watchtroll, which keeps moaning about SCOTUS improving the quality of US patents, even as recently as 4 days ago.

Their logic is fairly simple: more patents = good, fewer patents = bad.

"Why is it that patent lawyers are allowed to dominate not only media coverage about patents but also blogs, including ones with a name like IP Watch (suggestive of opposition to the 'IP' maximalists)?"That's it! Financial logic. For patent lawyers anyway...

We were rather disappointed to see that on the very same day IP Watch was again acting like platform of the patent microcosm (second time in a week), having published this post about Zeroclick, initially covered here back in early June.

Why is it that patent lawyers are allowed to dominate not only media coverage about patents but also blogs, including ones with a name like IP Watch (suggestive of opposition to the 'IP' maximalists)? The public needs to hear more from technical people, not legal professionals, whose skills involve name-dropping or 'pulling a Berkheimer', as we dubbed/called it back in May. The Patent Trial and Appeal Board (PTAB) almost never mentions Berkheimer in relation to inter partes reviews (IPRs). Neither does the Federal Circuit.

Recent Techrights' Posts

GNU/Linux Measured at All-Time High in Sweden
Can 'influencers' have played a role
GNU/Linux Becoming More Universal
It seems likely the end of Vista 10 coinciding with a sharp rise in memory prices (and now energy prices) will benefit GNU/Linux and therefore give us more to write about
Can Economies Like the American One Hang On?
The coming weeks will be "interesting" unless wars end
 
SLAPP Censorship - Part 32 Out of 200: Garrett Made Spurious Requests (Later Withdrawn) the Same Week Someone He Later Spoke to by E-mail Sent Threats to Our Webhost
The "plot thickens" because there's a multi-party tag-team act, as confirmed by Garrett after he had sworn on the Bible
IBM is a Dying Company, Nowadays It Kills Red Hat With Slop
when your last day is a national holiday in IBM's country
"Independence Drives" and Community-Run Sites
Independence in reporting is a much-valued trait
When Charlatans Are Only Good at Losing Money and Storytelling (e.g. About Investment in Them)
Wait till a a barrel of oil costs $300
What Apple Fans Are Missing
Apple is a bad company
The "Pale Blue Dot" Moment Had Returned
To many people, the "bitter-sweet" observation of how small we are
Saudi Arabia Does Not Rely Much on Microsoft/Windows
Putting aside politics, this is good for Free software
Almost 12 Years of Exposing Corruption in Europe's Second-Largest Institution
The "unready" President is now an abandoned President
Easter Moon Mission and Its Reminder of IBM's Demise
A lot of NASA operations now rely on GNU/Linux
When Power is Scarce and GNU/Linux Has Power
In Cuba, GNU/Linux has long enjoyed high adoption rates
Don't Totally Dismiss the 'Survivalists'
'Survivalists' or similar terms are used to describe a particular mindset of people who prepare for some really awful scenarios
Over at Tux Machines...
GNU/Linux news for the past day
IRC Proceedings: Thursday, April 02, 2026
IRC logs for Thursday, April 02, 2026
A Much Better Use of Fuel Than Slop
Something positive for a change
Hoping for Peace
There are still many things to be enjoyed, including nature and kind people
Gemini Links 03/04/2026: "Slide Rule Triple Multiplication" and End of "Picture Pages"
Links for the day
Rumours of Microsoft Layoffs This Season
Just how much trouble is Microsoft in at this point?
SLAPP Censorship - Part 31 Out of 200: Speaking About 20+ Years of Alleged Harassment/Defamation and High-Profile 'Targets' of Garrett
attempts were made to settle (in effect end the case) by the person who started the case almost half a dozen times along the way
In Asia, Windows is in Its Teens (Below 20%)
On a global scale, Windows is down to about 26%
Low Morale at IBM and Perception of Destructive Management
IBM is going nowhere, fast
Gemini Links 02/04/2026: Super Mario Galaxy Movie and New Antenna Instance
Links for the day
It Seems Like Google News Cracked Down on (Omitted, Delisted) a Lot of Slopfarms
There's no justification/point in spending so much energy just to plagiarise things poorly
Steam Survey for Last Month Says 5.33% Use GNU/Linux
big leap for GNU/Linux
Links 02/04/2026: Science News, Energy Scarcity, Oil Sold in Yuan
Links for the day
Links 02/04/2026: Apple Turns 50, Efforts To Ban VPNs
Links for the day
Gemini Links 02/04/2026: Kubernetes With FreeBSD, OFFLFIRSOCH, and Great Circle Distance
Links for the day
Dr. Andy Farnell on Microsoft Silencing or Deplatforming Opposition in the UK and Elsewhere
Microsoft as a king or a kind of "religion" one cannot question
Over at Tux Machines...
GNU/Linux news for the past day
IRC Proceedings: Wednesday, April 01, 2026
IRC logs for Wednesday, April 01, 2026
SLAPP Censorship - Part 30 Out of 200: The Time We Reported Abuse to Greater Manchester Police (GMP) and It Was Escalated to Its Cybercrime Unit
he started trolling and harassing me for criticising his employers' monopolistic and users-hostile agenda
'Modern' Cars Not a Rosy Industry
The current "modern" cars already have a shelf life similar to that of many toothpastes
Wrongthink Detector and Filter in "Think About the Children" Clothing
It is not about "age verification", it's a Trojan horse for social control
IBM Facilities Now Deemed Legitimate (Military) Target, Along With GAFAM Bases
Does IBM have any defences in place to protect against "downtime by explosions"?
What Happens When Some Large News Sites Turn to Slop and Spew Out Nonsense
LLM slop makes such grotesque mistakes abundant
Hardly Seeing Slopfarms Today, Even in Google News
Google's adventures with slop increased its debt significantly
Links 01/04/2026: Quantum Hype (Turing and Google), "US Fuel Prices Surge Past $4 a Gallon"
Links for the day
Gemini Links 01/04/2026: "Sacred Week of Cycling" and Zenity for Scripts
Links for the day
Losing Debian: Sruthi Chandran election flop
Reprinted with permission from Daniel Pocock
French judgment: parasitisme by FSFE & Matthias Kirschner (CO23.002709)
Reprinted with permission from Daniel Pocock
Microsoft Uses April Fools to 'Joke' About Inserting "Age Verification" (Surveillance) Into Linux
MinceR says the "lkml [message/page] one is April Fools or at least they're trying to pass it off as April Fools [however] the [GitHub] one was archived on the 8th and yesterday, so that probably isn't..."
IBM "Headcount Reductions" by Early Retirement and Death
The tragedy at IBM started 33 years ago on the first of April
Red Hat: Latin-1 character set under threat from Bishop Michael Martin, North Carolina
Reprinted with permission from Daniel Pocock
Links 01/04/2026: Microsoft GitHub Now Pushing Ads Into People's Code/Commits, Earth Overshoot Day Draws Nearer
Links for the day
What IBM and EPO Workers Have in Common: European Media Not Covering Very Major News (Press Became Dysfunctional)
Are IBM operatives working to scuttle the process of investigative journalism?
Free Speech in the United Kingdom When "Chilling Effect" is Increasingly Prevalent
If politicians cannot even use a term like "parasitic behaviour", then where do we as a society end up?
Oracle Lays Off Because of Debt and Commercial Issues, Not Slop
Like Scam Altman, Larry Ellison hangs around Cheeto King because he could use some bailouts in the form of government contracts or phony money with an incredible name like "Stargate"
The Real Reason Many Sites and Forums Shun Microsoft Lunduke
When forums say that they banned Microsoft Lunduke or don't want him mentioned it's probably because they are familiar with the "stench" that follows him around
Gemini Links 01/04/2026: Hallucinations, Stitching, and Type Systems
Links for the day
Lots of Layoffs at IBM, "Media Blackout" About Mass Layoffs at IBM's HashiCorp and Confluent Last Month
IBM is a dying company circling down the drain while manipulating or paying the media to pretend everything is fine
Microsoft Under Investigation by the UK's Competition and Markets Authority (CMA) for Abusive Tactics
What's noteworthy is that this is "set to begin in May"
Sounds Like Red Hat (IBM) Layoffs in Slop Clothing
This is an IBM policy. They try to justify staff cuts.
Over at Tux Machines...
GNU/Linux news for the past day
IRC Proceedings: Tuesday, March 31, 2026
IRC logs for Tuesday, March 31, 2026