Wednesday, May 13, 2009

Board Reverses 101 Rejection Using Machine Prong

Ex parte Andreas Myka and Christina Lindholm
Decided: May 13, 2009

In this decision, the Appellants were able to overcome a 101 rejection by "communicating" information between a master device and a slave device.

The claims at issue relate to bonding 'slave' devices, such as media capture devices, and instructing the devices to communicate captured media files with a specified set of metadata included.

Claim 14 recites:
A method for wireless bonding of devices and communicating media file transfer parameters, the method comprising:

monitoring, at a master device, an area of interest for the presence of potential bondable devices;

receiving, at the master device, a presence signal from a potential bondable device;

determining bond capability of the potential bondable device;

approving the potential bondable device as a bonded device; and

communicating, from the master device to the bonded device, media file transfer parameters, including definition of the media file metadata that is to be included with a captured media file.
Claim 24 recites:
A method for communicating media files and associated media file metadata from a bonded device to a master device, the method comprising:

bonding one or more slave devices to a master device according to predetermined media file transfer parameters communicated to the slave device from the master device; and

communicating a plurality of media files from the one or more bonded devices to the master device, the plurality of media files having metadata information as defined by the predetermined media file transfer parameters.
The Examiner originally rejected the claims under 101 using the "useful, concrete, and tangible result" test. The Board applied Bilski. Its entire analysis was:
The steps of claims 14 and 24 are performed by a master device or a bondable/bonded slave device. As argued by the Appellants, for example, the independent claims include 'communicating information between the master device and the bonded device.' Therefore, the methods recited in independent claims 14 and 24 are each tied to a particular machine or apparatus.
Result: 101 rejection reversed.

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