Bonum Certa Men Certa

In the Post-Alice Era, in Spite of the Berkheimer Hype, the Patent Microcosm Finally Admits There's No Turnaround

Who's still 'pulling a Berkheimer' anyway? Except for marketing purposes at patent law firms?

Pulling a Berkheimer



Summary: 35 U.S.C. €§ 101 or its high invalidation rate persists; much to the chagrin of Iancu at al Berkheimer isn't going to change that

THE U.S. Patent and Trademark Office (USPTO) is led by patent maximalists now. It made it more apparent a few days ago, as we noted a few hours ago.



Decisions from the Federal Circuit are being cherry-picked and in spite of support from even the highest courts -- SCOTUS included -- for the Patent Trial and Appeal Board (PTAB) and inter partes reviews (IPRs) Iancu at al attempt to undermine both. This underlines the extent of the trouble the Office now faces. Patent quality is certainly a priority at the courts; the Office is still pursing just numbers and then it wonders why people complain about low legal certainty associated with US patents.

"...the Office is still pursing just numbers and then it wonders why people complain about low legal certainty associated with US patents."It was recently shown, using an exhaustive analysis (published in Fenwick & West Blogs), that Berkheimer had made no real difference; the messengers were inadvertently showing that at times Berkheimer being brought up was a recipe for failure.

Those who are accustomed to 'pulling a Berkheimer' will no doubt continue to deny the facts, instead citing their "alternative facts". Days ago, in another rant among many about PTAB (all he does is ranting about PTAB), Mr. Gross wrote: "congrats to founder of this small start-up https://www.thesmartphr.com/ beating ridiculous Alice 101 patent rejection at PTAB: https://e-foia.uspto.gov/Foia/RetrievePdf?system=BPAI&flNm=fd2018006468-08-08-2018-1 … panel specifically calls out failure to follow Berkheimer memo on WURC standard!"

That's very rare!

As noted a few days ago, first in Lexology and then in JD Supra (press release), "Months after" (as in, more than half a year later) it is "Business as Usual" for 35 U.S.C. €§ 101 invalidations. They allude specifically to Berkheimer and Aatrix (days or weeks apart some time back in the winter). White & Case LLP's Bijal Vakil, Daren M. Orzechowski, Cale Tolbert and Michael Anthony Jaoude basically accept that all that "Berkheimer" hype was a lawyers' lie. Concluding as follows: "Although only a few months have passed, District Courts seem generally unfazed by the Federal Circuit's decisions in Berkheimer and Aatrix, continuing to decide cases at the motion to dismiss and summary judgment stages. Further time will tell whether these cases cause the disruption that many experts predicted five months ago or whether challenging eligibility will continue as usual."

"Those who are accustomed to 'pulling a Berkheimer' will no doubt continue to deny the facts, instead citing their "alternative facts"."No, not much has happened. We've been following this closely, as did Janal Kalis who gives another new example [PDF] when he writes: "The N. Dist. of California Killed the 23andMe Patent with Alice" (the usual, even at a district court, without a CAFC appeal).

Very good! Let's hope for many more invalidations such as these. This one, for a change, we suppose Gross and Kalis can actually celebrate a little because it impacts negatively a company indirectly connected to Google (which they loathe). ⬆

Recent Techrights' Posts

Criminalising Opposition to Fraud
slop causes social issues
 
SLAPP Censorship - Part 199 Out of 200: An American Burden on the British Legal System
A year ago (October 2025) the head of media (Jointly in Charge of the Media and Communications List), the judge in the Garrett case, said that this case was a waste of the court's money
EPO Management Wants Everything to be Done in Microsoft Spyware
In reality, this management should be ousted for normalising cocaine at the Office
The Register MS Does Not Properly Flag Its SPAM About Slop
Signs of desperation
Gemini Links 25/09/2026: Ljubljana, Tanana River, and Curse of Slack
Links for the day
Over at Tux Machines...
GNU/Linux news for the past day
IRC Proceedings: Thursday, September 24, 2026
IRC logs for Thursday, September 24, 2026
Supporters of winding-up process staking claims against Reform UK Party (CR-2026-007405)
Reprinted with permission from Daniel Pocock
Winding-up petition leaked before service on Reform UK Party Limited / Nigel Farage
Reprinted with permission from Daniel Pocock
Gemini Links 24/09/2026: Laziness, Outdoor Seating, "AngelNova’s Interview Malware and Its North Korea Connection"
Links for the day
Links 24/09/2026: Slop "Linked to Disturbing Culture of Sexual Assault"; "Zelensky Warns Russia’s War Will Expand if It Is Not Ended Soon"
Links for the day
Winding-up petition served on Reform UK Party Limited (Nigel Farage)
Reprinted with permission from Daniel Pocock
Appliances Should be Dumb
Any "Smart Home Appliance" is basically a thing that does not last long, does not work as advertised, and is generally unfit for purpose
SLAPP Censorship - Part 198 Out of 200: It Sounds Like Garrett is Now Sending People to Silence Critics (Including His Own Spouse)
This week Garrett is having a somewhat karmic experience
Links 24/09/2026: Slop Contaminating KDE, Slop-Focused Data Centres Have Severe Environmental Impact
Links for the day
SLAPP Censorship - Part 197 Out of 200: Garrett Became So Poor That He Wants Others (in Another Continent) to Pay for His Own Legal Work Being Faulty
They lie to courts
The Register MS Has Become a Slopfest
This is the behaviour of a perishing publisher
Gemini Links 24/09/2026: Requiem for a Season, Philosophy, Rube-Goldberg Machine, ROOPHLOCH 2026, and Git over Gemini
Links for the day
Over at Tux Machines...
GNU/Linux news for the past day
IRC Proceedings: Wednesday, September 23, 2026
IRC logs for Wednesday, September 23, 2026
IBM Grapevine: Development Outsourced to LLM Slop and It Results in Many Bugs
IBM is circling down the drain and every insider knows it
Microsoft Gives Many People the 'Booty' This Week, Not Counting PIPs (Silent Layoffs and 'Voluntary' Layoffs)
Microsoft PIPs allegedly target "20-25% in some teams."
Nearly 1,000 People at EPO 'Met' to Plan Further Strikes and Impending Action to Dethrone Corrupt Leadership
Exploring the purchasing "power" of EPO leadership (buying elections while doing cocaine in public)
Links 23/09/2026: Pax Silica Hub Ruins a Country for a Pyramid Scheme (Slop), Convicted Felon's Press Block Resembles Iran, Russia, China
Links for the day
Gemini Links 23/09/2026: Stuck, Gambling, Fury Road, IPFS, and More
Links for the day
The Register Got Paid Today to Spew Out "AI" Almost 50 Times (Keeping the Pyramid Scheme Buzzing in Headlines)
paid-for spam
SLAPP Censorship - Part 196 Out of 200: Sending Someone to Our Doorstep to Ship Approximately 5 KG of Legal Papers (Instead of to Our Representatives)
it is not about law, this is lawfare
IBM's Anderon Already Smells Like a Fraud and IBM Insiders Heckle the Lies From the Management
Sabine Hossenfelder recently made some videos which explain in simple terms why IBM is lying and has already lied about this for years
Links 23/09/2026: Mass-Surveillance by Clownflare and "Data Centre" Crunch Commences
Links for the day
Same Name/Brand, Not the Same Project/Product
What is Linux becoming?
Germany, Like Switzerland, Will Dump Microsoft's Proprietary Software and Disservices, Then Dump Windows for GNU/Linux
This impacts not only the Windows revenue; this corrodes any "rents" Microsoft was getting from "subscriptions"
3 Years Divorced From Americans
Next year we plan to pursue the UK's Court of Appeal
The Register MS Uses Slop About Slop (in Images)
Months ago we caught The Register MS using slop for text as well
There Are Likely Over a Thousand Internet Relay Chat (IRC) Networks Online, Net Gain of 16 Seen This Month by Andreas Gelhausen's netsplit.de
It's good that they're still tracking that sort of stuff
SLAPP Censorship - Part 195 Out of 200: Two Years Since Garrett, Graveley and Lozza Worked in Parallel to Censor Techrights
It began in September 2024, shortly after we had sued Garrett
Linux Kernel Becoming a Slopfest - Part 8 - In Conclusion
this can invite more SCO-like problems in the future
Microsoft Shuts Down More Studios, Morale Low, More Mass Layoffs Ahead of Reports
They pretend it's not happening or that it's a lot smaller than it actually is
Over at Tux Machines...
GNU/Linux news for the past day
IRC Proceedings: Tuesday, September 22, 2026
IRC logs for Tuesday, September 22, 2026
Gemini Links 23/09/2026: Ljubljana, Poetry, and FORTRAN
Links for the day