Bonum Certa Men Certa

Alice/Section 101 and PTAB Continue to Eliminate Software Patents While Patent Lawyers Attempt to Distract From Oil States (US Supreme Court's Decision)

Previously on Oil States:



A contract



Summary: In an effort to attract more business contracts, patent law firms give the impression that patent maximalism is alive and well in the US; in reality, however, the US undergoes some profound reforms and software patents are as toothless as they have been in recent years, not to mention that their elimination is only accelerating

THE US patent system gives us reasons for cautious optimism. Thus far, a few months down the line, the Director of the USPTO has not done anything abundantly damaging. He is under extreme pressure from the patent microcosm, which is trying to get him to become some sort of patent extremist like a certain disgraced (huge scandal!) judge who calls PTAB "death squads".



"Software developers aren't neutral on this subject; they want software patents destroyed."We have had our share of ups and downs with the USPTO in terms of expectations. A decade ago, for example, we were highly critical of its approach towards software patents. That was back when David Kappos and his predecessor ran it. This was before Michelle Lee did some extraordinary things with the people around her -- people who had helped introduce AIA (and with it PTAB).

Professor Michael Risch wrote this blog post a few days ago. He wrote about the impact of patents as a form of publication (for credit, documentation) -- more or less the original purpose of patents (temporary monopoly in exchange for publication, preservation of human knowledge). To quote Risch:

How valuable is patent disclosure? It's a perennially asked question. There are studies, like Lisa's [colleague], that attack the problem using surveys, and the conventional wisdom seems to be that there are niche areas that read patents, but for the most part patent disclosure holds little value because nobody reads them.

[...]

Even if one does not buy into the strong version of their conclusions, however, this study has a really important real world payoff: publishing patents has an effect. They are seen, and they affect the body of prior art in a way that limits future claims (at the very least) and increases citations (which makes searching easier). This alone is an important function; as Lemley, Sichelman, Wagner, and I argued in prior work, one of the costs of not having software patents through the 1970s was that there was no prior art to knock out all the software patents of the 1990's. This study confirms this for us.


Risch cites Lemley and others, then claims that software patents as a form of prior art is limited. We'd go further than this and say that there's no need for prior art, just release of source code. In addition to this, copyrights -- not patents -- should provide a solution to plagiarism/copycats. Risch's views on software patents have been covered here for many years and he recently wrote to me about it. He claims to be agnostic on the subject, but we still insist that software patents should be opposed. Software developers aren't neutral on this subject; they want software patents destroyed.

"It's like marketing in the form of a video (in the form of an 'article' at Mondaq)."Having reviewed the past week's news, we're still finding some references to the US Supreme Court. Most of these are self-promotional pieces from patent law firms, i.e. a form of marketing rather than impartial analysis. We're therefore not going to write so much about that. A few days ago we saw this self-promotional video from Cislo & Thomas LLP. We have never seen anything like this. It's like marketing in the form of a video (in the form of an 'article' at Mondaq). The summary says:

Veteran patent attorney Daniel M. Cislo discusses how patent litigation differs from other types of litigation.


Pure marketing. Why does that even enter news sites?

To give an example of marketing in the form of 'analysis' of the US Supreme Court's latest decision, here's a little something we caught a few days ago. The US Supreme Court has just declared IPRs Constitutional, but Jason E. Stach and Maureen D. Queler from Finnegan, Henderson, Farabow, Garrett & Dunner, LLP try to spin that as the exact opposite because they're patent predators. What does their title say? "Oil States Q&A: How Will Other Constitutional Concerns Affect IPRs?"

So the reader may be left with the conclusion that IPRs are still unconstitutional -- the very opposite of what the highest court in the United States has just said!

From their outline:

Oil States addressed constitutionality under Article III and the Seventh Amendment, but it did not directly address the other takings and due process issues raised by the Justices. Those issues will need to be addressed in future cases. However, many PTAB judges attended the oral arguments in November, and many more have listened to the argument or read the transcript. The sense in the profession is that the PTAB judges are acutely aware of the concerns raised by the Justices and they are working to quell those concerns. For example, it appears that the PTAB is now more willing to grant parties additional briefing, especially where denying that briefing might raise a due process issue. And since Chief Judge Ruschke has been at the helm, he has not expanded a panel to overturn an earlier institution decision. New Patent Office Director Iancu could also clarify that he will not use stacking as a way to "make sure [his] policies, [his] preferred policies are enforced," which is what Oil States' counsel argued predecessors had done.


That same firm (Finnegan) also wants you "[t]o listen to the podcast" by Joshua L. Goldberg, Cory C. Bell and Kevin D. Rodkey. They (Finnegan, Henderson, Farabow, Garrett & Dunner, LLP) focus on SAS Institute v Iancu -- the far less relevant decision. From the outline:

In SAS Institute v. Iancu, the Supreme Court addressed the question of, "[w]hen the Patent Office initiates an inter partes review, must it resolve all of the claims in the case, or may it choose to limit its review to only some of them?" The Court found that, contrary to the prior USPTO practice, the Board may not limit institution to only some of the challenged claims. Finnegan attorneys Joshua Goldberg, Kevin Rodkey, and Cory Bell join us now to discuss what happens now.


In summary, Finnegan would rather speak about SAS Institute v Lee (or SAS Institute v Iancu) and when it covers Oil States -- the far more important decision -- it misleads its audience, spinning the decision as the exact opposite of what it was. Coincidence? Mischief? Misconduct? We'll let readers decide, but this further erodes/exacerbates the image we already had in our minds (about patent law firms). What about Watchtroll? It's just hoping that the USPTO will change something. Given Oil States, nothing will change in favour of the patent microcosm. As for SAS Institute v Iancu, it has no considerable impact, just minor (it might slow PTAB a little but not curtail its function).

"The reason Berkheimer gets brought up so often is that they want a software patents resurgence or a PTAB slowdown."Looking at some other blogs of patent maximalists, Charles Bieneman is 'pulling a Berkheimer' again (he recently tried to coin terms like "Berkheimer Effect"). His blog post is titled "Berkheimer Prompts USPTO to Modify €§ 101 Exam Procedure", but this is relatively old news which is still subjected to public input. The patent maximalists are trying to make it sound very final and inevitable; it's not.

Bieneman didn't quite stop there; the blog's colleague, Bryan Hart, later on the day wrote about Oil States. But that was it. They wrote so many posts about Berkheimer (a far less important decision), but only one quick post about Oil States. Intentional? Malicious intent? Self serving? Whatever it is, it's consistent with the dishonesty that's plaguing the patent microcosm. Here's Patent Docs going on about Berkheimer again. They barely talk about Oil States and would rather go back in time (months!) to Berkheimer:

The U.S. Patent and Trademark Office will be offering the next webinar in its Patent Quality Chat webinar series from 12:00 to 1:00 pm (ET) on May 8, 2018. The latest webinar, entitled "Subject Matter Eligibility: Revised Guidance in view of Berkheimer v. HP, Inc." will be hosted by USPTO Deputy Commissioner for Patent Examination Policy Bob Bahr, will discuss the USPTO's recently-issued memorandum implementing changes to examination procedure in view of the Federal Circuit's decision in Berkheimer v. HP, Inc., which provides clarification on the subject matter eligibility analysis.


The reason Berkheimer gets brought up so often is that they want a software patents resurgence or a PTAB slowdown. Jonathan Cohen and Heenal Patel have in fact just given some bad advice on software patents, which are bunk (more or less worthless in courts). Here is what they wrote:

In general, software automation companies offer an attractive set of traits that include high recurring revenue bases, strong profit margins, high barriers to entry and robust cash flow generation, all of which can be protected by software patents.


What matters is that such patents cannot be properly enforced in courts. They're rejecting these. Nevertheless, quite frankly as usual, it seems as though the USPTO has just granted more such patents; this new press release sounds like algorithms for decision-making processes:

CleanSpark, Inc. (OTC: CLSK), a microgrid company with advanced engineering, software and controls for innovative distributed energy resource management systems, today announced that it has received two new utility patents from the United States Patent and Trademark Office.

The first Patent, "Establishing Communication and Power Sharing Links Between Components of a Distributed Energy System, US 9,941, 696 B2", awarded 4/10/2018, is a revolutionary patent that specifically addresses CleanSpark's engineering and data-analytics technologies, processes and procedures. The patent covers CleanSpark's ability to 'receive data from a plurality of sources within a microgrid, which is then analyzed to forecast power needs across the microgrid, or a combination of multiple 'fractal' microgrids, and then determining whether or when to share power with the requesting module.'


In the following new press release it sounds like algorithms for software-defined storage:

Excelero, a disruptor in software-defined block storage, was assigned US patent #9,971,519 today - its second US patent - governing a technique of performing NVMe access directly from a chip. This intellectual property (IP) will be utilized in upcoming SmartNIC-based versions of its flagship NVMesh Server SAN and provides customers with more efficient ways to use distributed NVMe using the open standard NVMf. Excelero is also in talks with NIC manufacturers about licensing this technology, which will help accelerate not just NVMesh, but also NVMf from any vendor.


We don't wish to delve into each new patent one at a time, but as the above couple of press releases may show, the USPTO can do just about anything it wants. But what's a lot more important is what courts will be saying. After Oil States we expect PTAB too -- not just courts -- to be able to undo such grants.

In conclusion, Oil States remains largely ignored by law firms, which would rather speak about old decisions that better suit their financial agenda. They want to attract clients who may foolishly pursue patents that lack 'teeth' in courtrooms. It's the applicants that suffer financially from these, whereas law firms just register more billable transactions. ⬆

Recent Techrights' Posts

No Noticeable Libera Chat Exodus After Code of Censorship (CoC) Scandal Earlier This Month
Libera Chat pissed off some people by unmasking the CoC's real purpose
The Local Staff Committee Munich (LSCMN) Speaks of Deterioration of Working Conditions at the European Patent Office (EPO)
"At least 3 days per week in the Office for an allocated office"
 
Links 15/10/2026: ALPRs Are Mass Surveillance, GAFAM Front Group ('New' EFF) Asks the Wisconsin Supreme Court to End Warrantless ALPR Searches
Links for the day
IBM RAs: "It's on Me"
IBM has no respect for the workers and it tries to hide the layoffs
Gemini Links 15/10/2026: Literature, Funerals, and Devices
Links for the day
The Efforts to Criminalise Opposition to a Ponzi Scheme Sold as "Super Intelligence" (Plagiarism Engines, Disinformation Generators)
Cops are becoming combatants for slop bros, i.e. they use power to promote a Ponzi scheme
Clownflare Sees Most Requests in Africa Coming From Android (Linux)
Android is the dominant platform
IBM's "RA Season" is Nearly Upon Us, But Tens of Thousands Are Already Marked for Removal With PIPs (as "Low Performers")
IBM is a dying company
Microsoft Has Confirmed It Had a Plan to Cut Azure (or Azure Costs) by 20%
So basically... yes! Microsoft did have a plan to slash Azure.
Red Hat Silent Layoffs Seem to Carry on Throughout This Month
How much longer will these silent layoffs (e.g. PIPs) carry on for?
Over at Tux Machines...
GNU/Linux news for the past day
IRC Proceedings: Wednesday, October 14, 2026
IRC logs for Wednesday, October 14, 2026
Netflix and Its Newest Rival Carry 100 Billion Dollars in Debt
What sort of economy is this?
Egypt: GNU/Linux Still Measured at About 5%
Egypt is a prominent African nation and economy
Gemini Links 14/10/2026: Time Allocation, English as a Fourth Language, and "Reading News Sources" in Geminispace
Links for the day
DRM Giant Announces Giant Layoffs (Netflix’s Debt is Huge)
It's not like operational costs are decreasing, they're climbing fast.
Intercontinental Brigading - Part III - Reporting Harassment From America to British Police
Why are they so hostile towards (and afraid of) cops?
Gemini Links 14/10/2026: GemPub, Randogoth Forge F-Droid Repo, Oddμ, and Kolibri
Links for the day
Bluewashing as Silent RAs: A "journey that began at Neudesic [...] and continued as part of IBM" inevitably came "to a close"
IBM can be antagonistic and reckless with whatever it buys
Links 14/10/2026: Houthi Attacks on KSA and Airstrikes Near Sudan-Egypt Border
Links for the day
No Coronation for 'Cocaine King' Campinos (Not Yet Anyway)
A flash update suggests perils exist and we must all wait until December as the position for EPO President may open
In Reddit, Moderators of IBM Subs Are Allegedly on IBM's Payroll (IBM Can Censor Discussions About IBM)
There also seem to be PIP layoffs in India
If Worthless Companies Are Valued at a Billion Dollars in the Slop Industry, Then What Is the True Worth of 'Trillion-Dollar' Companies?
Definitely not a bubble!
It Sounds Like Microsoft Plans to Lay Off Over 2,000 Azure (Microsoft) Workers as the Datacentre Business Brings Nothing But Epic Debt
Trillions in losses is not a solid business plan
IBM's Anderon is Like Theranos, But Will Anybody at IBM or Anderon Be Imprisoned for This Billion-Dollar Scam?
Will anyone ever be held accountable for it?
Microsoft XBox Won't Survive, Microsoft's CEO for This Perishing Business Turns to Slop
What the founder or father of XBox said about Asha Sharma earlier this year turns out to be accurate
Links 14/10/2026: So-called 'AI' Giants Go Bankrupt, "Military Will Hack the Election"
Links for the day
Indoor Season
we have more planned in order to improve navigation, accessibility, and workflows
Microsoft Demands That Staff Keeps Silent About the Mass Layoffs
Way to cause anger and ensure whistleblowers will go to the media
Microsoft Has Had Mass Layoffs in Azure Every Year Since 2020 and the Bleeding Continues Because It Misreports Earnings There
This is a bad week for Microsoft
Microsoft's International Mass Layoffs (Asia, Europe, Africa), Now Vietnam
A crisis that Microsoft is unable to hide
Over at Tux Machines...
GNU/Linux news for the past day
IRC Proceedings: Tuesday, October 13, 2026
IRC logs for Tuesday, October 13, 2026
Gemini Links 14/10/2026: Ceiling Fan, Fascism, Democracy, and Slop Being a Huge Bubble
Links for the day
Reports of Stress and Layoffs at Microsoft, Some People Laid Off Under the Guise of "Ban" (Gift From the Administration) and Many Sacked in India
"pip and gvsa" layoffs in India
ITwire Became Slop and Spam
The site still exists, but it's not what it used to be
W3C Died 20 Years Ago, Now We Live in a Post-W3C Era. Linux Foundation is 'Slop Bros', Now Linux is Becoming Unfree.
Torvalds is on the same side as Epsteingate
We're Way Past the Point Where Companies Announce or Declare Mass Layoffs
Layoffs are becoming hidden
Linux Kernel to Hide the Slop to Avoid Backlash, Suggestion Made by Former Microsoft Employee While Another Former Microsoft Employee is Worst Slopper/Culprit in Linux
Did Torvalds listen to slop antagonists?
Solicitors Regulation Authority (SRA) Besieged by Blind Justice UK, Politicians Increasingly Involved
"Today we have written to Members of both Houses of Parliament"
Vance Has Helped Microsoft Implement Secret, Silent Layoffs
Nothing excites Microsoft more than means by which to discard many employees without an obligation to tell shareholders about it
To The Register MS, Microsoft is the Only Brand That's at the Main Menu!
Consider that the Editor of The Register MS is a longtime faithful Microsofter
Microsoft's Collapse Will Continue, It's Drowning in Debt Now
Expect many more mass layoffs
Legal Self-Sufficiency
The more impact our work has, the more legal bullying will come our way
Plans for Winter in Manchester and London
From many perspectives, we're satisfied with the certainty and robustness of UK hosting, it's just that we're not yet robust/resistant enough to DDoS attacks
Customer Support Experience in 2026
Because the customer is never right
Microsoft Shutdowns in Africa, Mass Layoffs Also Reported This Week
further shutdowns
Links 13/10/2026: More Plagiarism Lawsuit Over Slop and AirAsia Needs State Help
Links for the day
Intercontinental Brigading - Part II - An Outline of This Series
What's to come
Gemini Links 13/10/2026: Dopamine Nation, Planner and Fatigue, and Moderators
Links for the day
Links 13/10/2026: Norway Fines Microsoft and Cops Can Creep on Airbnb
Links for the day
When Computers "Expire" Because Certificates Expire
People who promote Restricted Boot are liars. They lie for a living.
Over at Tux Machines...
GNU/Linux news for the past day
IRC Proceedings: Monday, October 12, 2026
IRC logs for Monday, October 12, 2026
Gemini Links 13/10/2026: Modern Science, Joplin, Luddites, and Lots More
Links for the day