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

NVIDIA Turns Out to be Serial Cheater, Stock Plunges 33% in 5 Weeks
The "slop bros" have long relied on patience and blind faith
 
Gemini Links 12/11/2026: A Firing of a Boss and Geminispace Growing Fast
Links for the day
Bill Epsteingate-Funded BBC "Totally Ignoring the $1.7 Trillion Wiped off NVIDIA Stocks"
Imagine how many pension funds are tied to this NVIDIA pyramid scheme
A Few Hours Before NVIDIA CEO Canned (and NVIDIA Shares Plunged) the NVIDIA-Funded The Register MS Published Paid Spam With "AI" 18 Times in It
Anything to inflate the bubble
Links 11/11/2026: NVIDIA Decapitated, "The Company That Published Fake Journalists in Sports Illustrated is Collapsing Dramatically"
Links for the day
Intercontinental Brigading - Part XXXXIX - We Didn't Start the Fire
It started in 2012
Photo Ops Are Liabilities
NVIDIA is not a "family business" and its CEO isn't some modest genius
NVIDIA’s Total Debt Trebled in Three Months!
Not the hallmark of a rich company unless its accounting is fraudulent
Adopting LLM Slop is Still Suicide
Suicide (in the literal sense) is also linked to adoption of chatbots
On Laundering Licences and Code
A "Second SCO" waiting to happen
The Cyber Show on Slop and the Ministry Of Truth in "Nineteen Eighty Four"
"cultural erasure" by slop
Intercontinental Brigading - Part XXXXVIII - Keeping Both Eyes on the Ball
One upside of these disputes is that they raise at least two very important issues concerning the law
Gemini Links 12/11/2026: Encryption is Easy, Human Emacs, and Legislation in Italy
Links for the day
Over at Tux Machines...
GNU/Linux news for the past day
IRC Proceedings: Wednesday, November 11, 2026
IRC logs for Wednesday, November 11, 2026
Links 11/11/2026: End of Novaya Gazeta (Assassinated by Putin) and North Koreans Too Poor to Buy Rice
Links for the day
Gemini Links 11/11/2026: The Tyrant’s Moat and Rants About Slop Causing Problems
Links for the day
Links 11/11/2026: Skydance Games and Boeing Hit By Layoffs, "Time Out for Timeouts"
Links for the day
IRC is for Communities, Social Control Networks Are for Broligarchs (by Broligarchs)
Unlike Reddit, it's not a company
JavaScript is the Problem, Not the Answer
Making the Web better is about making things better, not slapping more JavaScript 'walls' at it
Intercontinental Brigading - Part XXXXVII - "Making a False Complaint to Police is a Crime." (British Cops Aren't American Mercenaries)
"In the United Kingdom, the Foreign Enlistment Act 1819 and the Foreign Enlistment Act 1870 make it unlawful for British subjects to join the armed forces of any state warring with another state at peace with Britain."
The Label 'Anti-AI'
They make it sound like opposing plagiarism or cheating is an act of intolerance or hatred
Intolerance and Violence
Intolerance in the software world is not a new problem
António Campinos Hiding From Staff Amid Strikes, Won't Participate in Dialogue
They voted to continue striking until Christmas
Silent Layoffs at IBM (Rolling Layoffs), Now Curbs on H1B (Mostly Indian Applicants)
Little will change at IBM except the gravity (global distribution) of its workforce will go east
Links 11/11/2026: Moving from Proton to Posteo and "Floating in Space"
Links for the day
Over at Tux Machines...
GNU/Linux news for the past day
IRC Proceedings: Tuesday, November 10, 2026
IRC logs for Tuesday, November 10, 2026
Intercontinental Brigading - Part XXXXVI - Attempts to Kill Critics
"Epstein contacted Cambridge academics about research funding"
Gemini Links 10/11/2026: Running, Tektronix, and "Smallnet Information Services Zig Port"
Links for the day
Corporations Don't Lose 2 Trillion Dollars in 'Value' Over a 'Dick Story', This is an Overvaluation and Belated Correction
Nvidia is down, down, down again
Links 10/11/2026: "50 Years of Project Censored" and NVIDIA's Collapse Continues
Links for the day
NVIDIA Down About 30% in 5 Weeks, When Does the Media Call It "Bubble" Rather Than Frame It as Sex Scandal?
they'll find a way to blame "China"
Surreal Times
NVIDIA's shares fell 27% in 5 weeks
Links 10/11/2026: "Jensen Huang Could Face $81 Billion Divorce Bill" and "Nvidia Shareholders sue Jensen Huang"
Links for the day
Over at Tux Machines...
GNU/Linux news for the past day
IRC Proceedings: Monday, November 09, 2026
IRC logs for Monday, November 09, 2026
Gemini Links 10/11/2026: Open Problem in Computer Science Due to Bloat and "Queueing Nine Hours for an iPhone"
Links for the day