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

Links 04/11/2026: Slop Helps Break Laws and Scam Altman Pretends Chatbots Are Persons
Links for the day
Intercontinental Brigading - Part XXXVII - Tasteless, Tactless Time for "Virtue-Signalling" (When Your Actions Are Much Like the GOP's)
Violence by cops isn't a "leftist" thing
United Arab Emirates: GNU/Linux at Over 8%
According to statCounter
As XBox Goes Out of Business Helen Chiang Adds Insult to Injury
XBox sales are worst in 25 years
Intercontinental Brigading - Part XXXIV - Women as Hostages, Even Spouses
First he put his own spouse behind bars by accusing the spouse of what he himself seems guilty of
 
Intercontinental Brigading - Part XXXIX - Crime Numbers Regarding GGG (Americans) and Why Those Still Matter
Time does not undo the actions
Intercontinental Brigading - Part XXXVIII - Telling the Police About the Defamatory Blog Where Posts Targeted My Wife and I (From Across the Atlantic Ocean)
Two years ago we spoke to cops a lot
The Register MS is Losing Money Again, Based on The Register MS
Selling out didn't pay off for very long
There Are No "Layoffs" Anymore, Layoffs Got Rebranded
We're entering bizarre times when layoffs are said to be "down" (according to the regime that suffered a 'bloodbath' in the election) because companies quit using the term "layoffs"
Gemini Links 05/11/2026: Rivers of London, Soul Cakes, STMicroelectronics, and Slop
Links for the day
The Register MS Has Just Published Fake Article With "AI" 84 Times in the Page Because It Was Paid to Do This!
Astounding number of mentions of "AI" (84 in total)
Over at Tux Machines...
GNU/Linux news for the past day
IRC Proceedings: Wednesday, November 04, 2026
IRC logs for Wednesday, November 04, 2026
Gemini Links 04/11/2026: Abacus and Spare IT Equipment
Links for the day
Viet Nam and Thailand at High Adoption Levels of GNU/Linux, Other Nations Nearby Are No Exception
Helen Chiang and her colleagues say it's a "clown show" at Microsoft
Richard Stallman on What It's Like to be Threatened by Strangers With Software Patents
We hope that some EPO insiders will take time to listen to this talk
Stealth Layoffs at IBM (PIPs and Bailouts)
string of reports or unverified hearsay
Steven Vaughan-Nichols is Slop
Just look at this
The Register MS is "Hosting a Dinner" for Sponsors
Remember that The Register MS keeps publishing spam about "AI"
Intercontinental Brigading - Part XXXVI - A Potent Microsoft Threat to Administration of Justice Globally (Not Just Fair Elections)
Breaking into machines to cover up one's own crimes
Intercontinental Brigading - Part XXXV - When One Does Not Understand Security (Nor Ever Pursues Security)
One might therefore conclude that Garrett is a proponent of American back doors
Links 04/11/2026: "Democratic Establishment" Wins Big and "Pentagon Sued Over Hegseth’s New “Future of Warfare” Committee Led by Musk"
Links for the day
A Geminispace Tally
That's not the Web, it is an alternative to it
Intercontinental Brigading - Part XXXIII - Shooting the Messenger is a Presidential Tactic
why our ministers are looking for ways to fix the law.
Andy's Latest Writings About Proton CEO Andy Yen, "JavaScript Required", and Slavery in Technology
Andy (of The Cyber Show) has some new material
Intercontinental Brigading - Part XXXII - Malfunctions Reported in Windows Voting Machines (as Usual)
"There are always problems," Ryan told us
Gemini Links 04/11/2026: GoAccess, Adopting Gopher, and Twisty Passages
Links for the day
Over at Tux Machines...
GNU/Linux news for the past day
IRC Proceedings: Tuesday, November 03, 2026
IRC logs for Tuesday, November 03, 2026
"The Judge Accepted That Mrs Schestowitz Had Been the Subject of a Vicious Campaign of Online Harassment"
That's consistent with how they men treat women
Intercontinental Brigading - Part XXXI - Microsoft and Promoters of "Secure Boot" Are to Blame
the important thing is that the dictator and Microsoft can remotely control all computers
Links 03/11/2026: Science Around "Near-Death Experiences" and "Do Animals Grieve?"
Links for the day
Gemini Links 03/11/2026: Guitar, 3D-Printable Electric Spinning Wheel, Against Haven Social, and More
Links for the day
Intel Corporation Down Over 51% in One Month, the US Bailout Didn't Work
Is the slop industry [sic] next?
Microsoft European Development Centre (EDC) Next to be Culled?
No time for that anymore
Intercontinental Brigading - Part XXX - Breaking This Year’s Election Process With Bug Doors in Restricted Boot
Thankfully here in the UK we typically still vote with paper and pencil
Mass Layoffs at SUSE, Over 10% of Staff Gone
Ignore their excuses
When You're a Software Developer and They Tell You That Your Occupation is Dead or Dying in Order to Sell Dysfunctional Offerings Based on Hype (and Plagiarism)
Disbelief is a strength when companies borrow trillions of dollars to sell a dud and construct a pyramid scheme
Links 03/11/2026: Slop-Tied Debt is Becoming a Crisis (Lenders Panic), "Ukrainian Journalists Urge Global Media Not to Look Away From Russian Aggression"
Links for the day
Malaysia Seems to be Exploring Digital Independence With GNU/Linux and More
not too bad
Microsoft Windows is Crashing in Republic of South Korea
Like in Japan, they seem to be shutting the lid on decades of Microsoft-isms
Think Less, Aim for Less (When It Comes to Hardware)
An abundance of hardware being wasted on a pyramid scheme will become a cautionary tale one day
Gemini Links 03/11/2026: Stargazing, Linux-Powered Prism "Ambient Computer", and Abandoning Streaming Disservices
Links for the day
GNU/Linux Made Big Strides in Portugal This Year
Microsoft had many layoffs in Portugal in recent years
GNU/Linux in Argentina Now Measured at 8% "Market Share"
Argentina is known for exporting skilled footballers, not advanced technology, but it has a large population, which we can hope will dump Windows
Microsoft is Borrowing Loads of Money While Telling 60,000 Workers to Take the "Offer" and Leave, Microsoft Wants Bailouts From the Dictator
Vote in elections and also vote with your wallet
Microsoft and Spoilt Food
Some whistleblowers may be needed here
Intercontinental Brigading - Part XXIX - Undermining US Election While Engaging in Lawfare in England (BBC) Against Publishers That Cover Anti-Election Violence
The elephant in the room is back doors in voting machines
Over at Tux Machines...
GNU/Linux news for the past day
IRC Proceedings: Monday, November 02, 2026
IRC logs for Monday, November 02, 2026