Geoscope Technologies Pte. Ltd. v. Google LLC & Apple Inc., decided May 2, 2025

Case Name: Geoscope Technologies Pte. Ltd. v. Google LLC, Apple Inc. Case Numbers: 2024-1003, 2024-1018 Court: United States Court of Appeals for the Federal Circuit Decision Date: May 2, 2025 Judges: HUGHES, MAYER, STOLL Disposition: Affirmed

Subject Matter: Patent eligibility under 35 U.S.C. § 101 of claims related to determining the location of mobile devices.

I. Overview

This is an appeal by Geoscope Technologies Pte. Ltd. ("Geoscope") from the final judgments of the United States District Court for the Eastern District of Virginia, which held that several claims of Geoscope's patents were directed to patent ineligible subject matter. The Federal Circuit reviewed the district court's decision under the law of the Fourth Circuit and affirmed the lower court's findings. The core issue revolves around whether Geoscope's claims, which relate to determining mobile device location by comparing measurement data from unknown locations to a reference database, represent patent-eligible inventions or merely abstract ideas.

II. Patents and Asserted Claims at Issue

The appeal concerns the patent eligibility of the following claims:

• U.S. Patent No. 8,406,753 (the "’753 patent"): Claims 1 and 32.

• Claim 1 describes a method involving providing calibration data for calibration points, generating grid points from this data, receiving a network measurement report from a mobile device, evaluating the report against the grid points, selecting a set of grid points based on criteria, and determining the mobile device's location based on the selected grid points.

• U.S. Patent No. 7,561,104 (the "’104 patent"): Claim 2. (Part of the "'104 patent family" which also includes the '358 and '494 patents and share substantially identical specifications).

• Claims 1 and 2 (Claim 2 is dependent on Claim 1) describe a method for determining location by providing a database of calibration data, collecting observed network measurement data including signal characteristics, determining the greater magnitude signal characteristic, modifying the observed data using this characteristic, and comparing the modified data with the database. Claim 2 specifies that the database comprises calibration data for one or more non-uniform grid points.

• U.S. Patent No. 8,400,358 (the "’358 patent"): Claim 18. (Part of the "'104 patent family").

• U.S. Patent No. 8,786,494 (the "’494 patent"): Claims 4 and 26. (Part of the "'104 patent family").
  

III. District Court Decisions (Affirmed by the Federal Circuit)

The District Court for the Eastern District of Virginia granted judgment on the pleadings for Google and Apple, finding the asserted claims patent ineligible under 35 U.S.C. § 101, applying the two-step framework from Alice Corp. v. CLS Bank International.

• '753 Patent: The court held that the asserted claims were "directed to the abstract idea of determining an unknown location by comparing information about known locations organized in a database against measurements from a mobile device." (Google Decision, 692 F. Supp. 3d at 581). The court found these claims failed to disclose "a new source or type of information, or new techniques for analyzing it." (Id. at 583).

• '104 Patent Family: The court determined these claims were also patent ineligible, viewing them as "linked to the same abstract idea of data collection, modification, and analysis." (Id. at 575). The court found no "claim elements that amount[ed] to significantly more than the abstract idea of determining location based on data." (Id. at 580).
  

IV. Federal Circuit's Reasoning

The Federal Circuit conducted a de novo review of the district court's grant of judgment on the pleadings.

A. The '753 Patent

Applying Alice step one, the court considered the claims in their entirety and found them "directed to determining the location of a mobile device by collecting data about known locations (such as information about the properties of signals transmitted by different cell towers), organizing that data in a database, and then comparing that data to measurements from the mobile device." (Opinion, p. 6-7).

The court reiterated that claims directed to "collecting information, analyzing it, and displaying certain results of the collection and analysis," without more, are abstract. (Opinion, p. 7, citing Elec. Power Grp., LLC v. Alstom S.A., 830 F.3d 1350, 1353 (Fed. Cir. 2016)). The fact that the claims relate to location data does not make them less abstract. "even if a process of collecting and analyzing information is limited to particular content or a particular source, that limitation does not make the collection and analysis other than abstract." (Opinion, p. 7-8, citing SAP Am., Inc. v. InvestPic, LLC, 898 F.3d 1161, 1168 (Fed. Cir. 2018)).

At Alice step two, the court rejected Geoscope's argument that the claims contain an inventive concept, specifically regarding the claimed "grid points." Geoscope argued that the grid points are not conventional but are dynamically generated based on calibration data and are not necessarily uniform, leading to technological benefits like faster and more accurate geolocation. However, the court found "nothing in the language of the asserted claims of the ’753 patent that offers a specific and concrete advance in geolocation technology." (Opinion, p. 8). The claims merely describe known techniques for geolocation using signals from known locations.

The court emphasized that the claims describe the concepts of collecting, organizing, and analyzing data in broad, results-focused terms, "bereft of any specific guidelines on how to perform the basic functions they recite." (Opinion, p. 9). For example, claim 1 does not specify the "characterizing parameters" for the calibration data or the "predetermined criteria" for selecting a set of grid points.

Crucially, the court found that the claims do not explain how the grid points are generated from calibration data or suggest the use of any new technology in this process. The court highlighted that "The [section] 101 inquiry must focus on the language of the Asserted Claims themselves, and the specification cannot be used to import details from the specification if those details are not claimed." (Opinion, p. 10, citing ChargePoint, Inc. v. SemaConnect, Inc., 920 F.3d 759, 769 (Fed. Cir. 2019)). Merely generating one form of information (grid points) from another (calibration data) is insufficient for patent eligibility.

The court also dismissed Geoscope's argument that the district court ignored adopted claim constructions, stating that the constructions are consistent with the finding of ineligibility because the claims are drafted at a high level of generality. In conclusion, the '753 patent claims are not directed to any specific improvement in computer technology or signal transmission and measurement functionality, relying instead on existing technology as a tool for data comparison.

B. The '104 Patent Family

The Federal Circuit also concluded that the asserted claims of the '104 patent family are patent ineligible under § 101. These claims involve determining location by collecting, modifying, and comparing data. The court found these claims, like those of the '753 patent, "at most recite abstract data manipulation," failing Alice step one. (Opinion, p. 12, citing Hawk Tech. Sys., LLC v. Castle Retail, LLC, 60 F.4th 1349, 1358 (Fed. Cir. 2023)).

Geoscope argued that the "modifying" step in these claims provides an inventive concept by addressing disparities between indoor and outdoor data, improving accuracy. The court rejected this, noting that the claims are not limited to eliminating indoor/outdoor disparities, as the terms "outdoor" and "indoor" are not in the claims. Furthermore, while the claims recite "modifying," they "do not specify precisely how such modifications should occur or recite any new technology for performing such modifications." (Opinion, p. 13).

The court addressed specific claims within the family:

• Claim 18 of the '358 patent: Invokes the use of "circuitry" for data manipulation. The court stated that reciting conventional components functioning in their expected manner is insufficient for § 101 eligibility. "If a claim’s only ‘inventive concept’ is the application of an abstract idea using conventional and well-understood techniques, the claim has not been transformed into a patent-eligible application of an abstract idea." (Opinion, p. 14, citing BSG Tech LLC v. BuySeasons, Inc., 899 F.3d 1281, 1290–91 (Fed. Cir. 2018)).

• Claim 2 of the '104 patent and claim 26 of the '494 patent: Require routine mathematical calculations. The court reiterated that mathematical algorithms for performing calculations, without more, are patent ineligible. "Courts have long held that mathematical algorithms for performing calculations, without more, are patent ineligible under [section] 101." (Opinion, p. 14, citing In re Bd. of Trs. of Leland Stanford Junior Univ., 991 F.3d 1245, 1250 (Fed. Cir. 2021)).
  

V. Key Takeaways

• Claims directed to collecting, analyzing, and displaying information using conventional components, without a specific improvement in computer technology or a concrete application of an underlying abstract idea, are likely to be found patent ineligible.

• Merely applying an abstract idea using conventional and well-understood techniques is not enough to transform the idea into a patent-eligible application.

• Claims must specify how the recited functions are performed and demonstrate a specific technological improvement, rather than simply describing desired results or relying on generic functional language.

• Claim language, not the specification, is the focus of the § 101 inquiry. Details from the specification cannot be used to import inventive concepts if those details are not claimed.

• The presence of location data or routine mathematical calculations in a claim does not automatically confer patent eligibility if the claim is still fundamentally directed to an abstract idea of data manipulation.