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

Enjoy the Giving/Sharing, Not Taking
We've long supported what we believed in, even with the little money we had
SLAPP Censorship - Part 190 Out of 200: Plagiarism, Back Doors, and Sabotage of Linux
This can go on for a decade or longer
 
Links 20/09/2026: "Google Now Asking For Users’ Video Selfies" and Energy Prices Set to Rise
Links for the day
Links 20/09/2026: Amazon Layoffs, Flock 'Buyouts' (Silent Layoffs)
Links for the day
USCIS and Microsoft Rumours: Curbs on Lowering Salaries by Importing Cheaper Replacements?
It seems like Microsoft's mass layoffs and efforts to cheapen the workforce face obstacles
Gemini Links 20/09/2026: "Music While Working" and Radio Silence
Links for the day
Clownflare Data From Canada
We've like to think many people are attempting to install GNU/Linux over the weekend
Linux Kernel Becoming a Slopfest - Part 5 - Kernel Dependency on Plagiarism Giant Microsoft is a Death Blow to Any Kernel
Microsoft is bringing copyright-infringing slop into Linux
GNU/Linux Has Grown a Lot Lately
Based on Clownflare
Over at Tux Machines...
GNU/Linux news for the past day
IRC Proceedings: Saturday, September 19, 2026
IRC logs for Saturday, September 19, 2026
Links 19/09/2026: Many Patents Become Candidates for Annulment and Linux [sic] Foundation Takes More Slop Money to Promote Malicious Bots
Links for the day
Gemini Links 19/09/2026: The Fundamental Human Assets, The History of Gopher's "i" Type, and ROOPHLOCH 2026
Links for the day
Links 19/09/2026: "OpenAI and Microsoft Knew They Were Starting a ‘Doom Loop’ [of Mass Plagiarism 'Normalised' by Brute Force] for the web", Calling It "Hey Hi"
Links for the day
8 Series Going on at the Moment in Techrights
4 series about SLAPPs and related matters
Linux Kernel Becoming a Slopfest - Part 4 - Outsourcing to Microsoft, Approaching 10 Gigabytes
Can we blame Microsoft for those DDoS attacks? Partly.
SLAPP Censorship - Part 189 Out of 200: A Terrible Idea to Condemn Projects for Using Slop 'Code' When Your Own Employer Does This (and Profits From Every Company Doing So) or to Call Distros 'Not Secure' While You Advance Back Doors
"I don’t want a back door. I want a front door."
Software Freedom Day 2026 is Today, Week-long Celebration in Brazil
In Brazil, Clownflare reckons about 1 in 20 laptops/desktops might use GNU/Linux already
Red Hat Lost 2,000 Staff (Net Loss)
Maybe by year's end it'll be a 20% reduction
Over at Tux Machines...
GNU/Linux news for the past day
IRC Proceedings: Friday, September 18, 2026
IRC logs for Friday, September 18, 2026
Gemini Links 18/09/2026: Setting Goals, Tiredness, and Admissions From LLM Purveyors It Was All Along About Building Plagiarism Engines Sold as "Intelligence"
Links for the day
Links 18/09/2026: Microsoft Boasted Slop is Just Copyright Infringement/Plagiarism, Floods in Europe
Links for the day
Slop Ruins Development and Reverse Engineering, It Rewards Retarded "Slop Kiddies" (to Quote Andy ‘TheFlow0’ Nguyen)
Slop is just a fatal cancer that kills the body, then dies with the body it killed
Internet Relay Chat (IRC) and Mailing Lists Are Still Better Than Discord, Slack, and Discourse
Discourse is "open" "bossware"
Links 18/09/2026: Disgust Over LLMs and Why "Agents" (Bots) Are Nothing More Than "Spam"
Links for the day
Software Freedom Day is Tomorrow
events coming
Illegal and Unconstitutional Tribunal That SLAPPs Critics Does the Illegal and Unconstitutional: It "Rubberstamps Software Patents"
This is not a legal system. This is mafia.
Privilege in 'Linux' Foundation (Double Standards) and What the FSF Should Avoid Doing
If RMS can talk about politics, others too should be able to talk about politics
Seems Like Many Microsoft Layoffs Are Going On Right Now (Forever Layoffs)
Like IBM, Microsoft hopes shareholders will not know of morale and financial problems
More Threats From the Person of Restricted Boot Infamy
Remember this is the man who is the principal purveyor of restricted boot and who landed restricted boot in Linux
Snooping EPO Management, Sniffing Up Every Staff Action
It this a problem for whistleblowers? Of course.
Don't Do That
Options do exist. People should exercise freedom.
Iran Has Debunked GAFAM and Cloud Computing as Safety of Data
Cloud of smoke?
Over at Tux Machines...
GNU/Linux news for the past day
IRC Proceedings: Thursday, September 17, 2026
IRC logs for Thursday, September 17, 2026
SLAPP Censorship - Part 188 Out of 200: Used, Then Discarded, by Microsoft (as We Predicted All Along, It's Always Like That)
The longer they carry on with it, the more scandalous this will get
Linux Kernel Becoming a Slopfest - Part 3 - Besieged by LLM Bots, Now Hiding Behind a Wall of JavaScript
The series began 3 days ago
Gemini Links 18/09/2026: Modern Linguistic, Boxing, Turning 40, and Solar MiniServer
Links for the day