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

Google "Hey Hi" (Slop) Having a Stroke, Thinks I am Married to the Grandmother of My Grandfather
Seriously!
Beehiiv and Substack Are Platform Lock-in (Similar to Vendor Lock-in), Don't Use Beehiiv and Substack (and the Likes of These)
Proprietary platforms are a problem. Some people "get it" sooner than others.
Jim Zemlin/Linux Foundation Selling Anthropic Slop After Getting Bribed for Slop Marketing ('Linux' Foundation is a Pay-to-Say For-Profit Marketing Company That Buys and Manipulates the Media Based on False Pretences)
Look what they've done to Steven Vaughan-Nichols (SJVN)
The Corrupt Lecture the Non-Corrupt - Part XX - EPO Management's Unified (One) Voice or Policy is, Doing Cocaine is OK When You're a Friend and/or Family of President Campinos
The management needs to resign to save the Office
 
IBM Falls to One-year Low
At one point or threshold does the Board (controlled by the CEO) sack the CEO?
Gemini Links 12/05/2026: On Astronomy and Stargazing, Coyote Time, and Freenom
Links for the day
Links 12/05/2026: Data Centres Destroying Neighbourhoods, "Care Workers Are Saying No to 24-Hour Workdays"
Links for the day
Richard Stallman to Give Public Talk in Erlangen, Germany (Next European Tour)
Seems like a large room
If IBM Suddenly Vanished in the 1980s, There Would be Chaos. Not Anymore.
IBM's management has rendered IBM more irrelevant than ever before
Gitlab is in Trouble and Its Shares Have Collapsed
Down almost 80% since it began [...] The real issue has nothing to do with slop, it is a lack/loss of customers and erosion of the company's theoretical "value"
Microsoft: Mass Layoffs Are "Offers" (Like "Job Offers"), Culling Experienced and Highly-Paid Staff is "Softer Workforce-reduction Strategy"
Media sites that play along with those lies don't do journalism, they're in the PR industry
Under IBM, Mass Layoffs at Red Hat No Better Than Oracle Under Larry Ellison (Treating Workers Like Disposables - Even Enemies - Overnight)
under IBM the respect for the worker (or peer) does not exist
The Slop-Amplified Fear of Privilege Escalation (Local, Not Remote) in Linux, the Kernel
we are meant to assume this is no better and no worse than Microsoft intentionally putting back doors in everything, even encryption
GitLab the Latest Company to Do Mass Layoffs and Use Slop as the Go-to Excuse (GitLab Users Should Worry Too)
This round of layoffs (disguised as something else) has nothing to do with slop ("hey hi"). It's about commercial problems.
Technology Not Meant to Last
A society apathetic towards declining production (or manufacturing) standards will end up ripped off
statCounter Cannot 'See' Chinese Operating Systems That Gain Many Millions of Users Per Month
There is no way for statCounter to recognise or show the market share of HarmonyOS
SLAPP Censorship - Part 74 Out of 200: The Basis of My Lawsuit Against Alex Graveley, Who Helps Garrett Stack the Docket in Another Continent
claim against the Serial Strangler from Microsoft
Update on Slop About "Linux"
"Linux" is a term many people are interested it, so it's not shocking that slopfarms target it
Over at Tux Machines...
GNU/Linux news for the past day
IRC Proceedings: Monday, May 11, 2026
IRC logs for Monday, May 11, 2026
GAFAM (Microsoft) "Cloud Computing" Means Another Country's Military Accesses All Your Data
reminder that confidentiality and Clown Computing are complete opposites
Another Discrimination Lawsuit Against IBM and Workers Say IBM Culls Older Workers (Just Like Microsoft)
If IBM fails to retain some of the smartest people, then what is the future of IBM?
Gemini Links 12/05/2026: Android Nostalgia and Switching to Guix
Links for the day
Links 11/05/2026: Another Oracle Setback and Mass Layoffs in Iran
Links for the day
Gemini Links 11/05/2026: Older Can Be Faster and Textmode Workflow
Links for the day
Links 11/05/2026: The Solicitors Regulation Authority (SRA) Admits It Only Reacts When It's Too Late (Damage Already Done), Ombudsman’s Animal Cruelty HK Report
Links for the day
If It Takes You a Second to Serve (or Receive) a Page, That's Definitely Too Slow
For speeds at milliseconds (e.g. for pages to fully load in a tenth of a second) the pages must be ready to be sent as soon as they're requested
It's Not About Speed, It is About Patience and Adherence to Truth, Principles, Scientific Integrity
attacks on us only ever made us stronger - a lesson that our adversaries have learned the hard way
Cyber Show Does it Like Techrights: Static and Gemini Protocol as 'First-Class Citizen'
HTML and GemText (over Gemini Protocol) would be rendered in tandem
Libya's Share on the Web: 5.2% GNU/Linux
GNU/Linux has hit an all-time high there
SLAPP Censorship - Part 73 Out of 200: Microsoft's Graveley and Garrett Remain Closely Connected in May 2026 ("Tag-Teaming" Against Bloggers in Another Continent)
The phrase "judge a person by their friends" seems applicable here
Codecs and Software Patents - Part VI - The European Patent Office, Nokia, Microsoft, Sisvel, and More
Whatever Nokia used to be, it's certainly not an ally and a lot of the turmoil at the EPO is the fault of companies like Nokia
Discussions About When the Axe Falls at IBM/Kyndryl (11,000 Layoffs Estimated)
"Kyndryl restructuring should reduce overhead functions and reduce the number of managers that lack technical knowledge"
A World After Microsoft (and GAFAM) and After GitHub Shuts Down
the only growth area is debt
Fake News, Propaganda, and Misinformation: Microsoft Investing Money It Does Not Have in "Hey Hi" (for "Entertainment Purposes" Only)
This will not end well
Today the Whole European Patent Office (EPO) is on Strike and Next Monday an Even Bigger Strike
the media refuses to cover these and is thus complicit
The Corrupt Lecture the Non-Corrupt - Part IXX - EPO Management Speaks of Reputation and Integrity While Putting Cocaine Addicts in Management
If the EPO values its "reputation", then it needs to start by ousting the management
Over at Tux Machines...
GNU/Linux news for the past day
IRC Proceedings: Sunday, May 10, 2026
IRC logs for Sunday, May 10, 2026
Links 11/05/2026: Security Breaches, Politics, and Energy Crunch
Links for the day
Gemini Links 10/05/2026: "Accidental Cameras" and "Addictive" Interfaces in Social Control Media
Links for the day
Codecs and Software Patents - Part V - A Reminder That GAFAM and the European Patent Office (Which Serves American Monopolists) Do Considerable Harm to the Commons and Culture
some 'breaking' developments
Gemini Links 10/05/2026: Inkscape, Guix, and Alhena 5.5.8
Links for the day
The "Alicante Mafia" at the European Patent Office (EPO) Experiments With New Methods for Crushing Industrial Actions
Open letter to VP1 and the COO [...] What does this tell us about the status quo at the European Patent Office, Europe's second-largest institution?
The Corrupt Lecture the Non-Corrupt - Part XVIII - "The European Patent Office (EPO) has a zero-tolerance policy for fraud" (except when managers do it)
The guidebook of the EPO says fraud is not to be tolerated, but who enforces or revisits such "Red Lines"?
Links 10/05/2026: Hantavirus Brings Back 'Contact Tracing' Surveillance, "Staple Food Prices Soar in Iran"
Links for the day
Microsoft XBox Staff Know They're in Trouble, They Try to Unionise Ahead of Mass Layoffs
As the slang goes, it's going to be a "bloodbath"
Links 10/05/2026: Fake Suicide Notes and New EU Restrictions on Slop
Links for the day
SLAPP Censorship - Part 72 Out of 200: Microsoft's Graveley and Garrett Signed Documents That Hold Them Accountable to Truth and Liable for Lies
Such collaborations are unsavoury and apparently unprofessional, too
Over at Tux Machines...
GNU/Linux news for the past day
IRC Proceedings: Saturday, May 09, 2026
IRC logs for Saturday, May 09, 2026
Gemini Links 10/05/2026: Travelling to Van and "Dark Mode" as Passing Fad
Links for the day