## Facts

- Contour IP Holding LLC owned U.S. Patent Nos. 8,890,954 and 8,896,694 (a continuation of the ’954 patent), directed to portable point-of-view (POV) digital video cameras configured for remote viewing and control.
- The patents described a problem in action-sports use: cameras are often mounted where users cannot easily see the camera, making it difficult to monitor recording in real time or adjust settings and framing.
- The claimed approach used multiple video streams generated and handled in parallel, such as recording a higher-quality stream locally while transmitting a lower-quality stream wirelessly to a remote device for real-time preview and camera control.
- Contour sued GoPro, Inc. in the Northern District of California, alleging infringement by several GoPro POV camera products.
- After years of litigation, GoPro moved for summary judgment that the asserted claims were patent-ineligible under 35 U.S.C. § 101.
- The district court granted summary judgment, concluding the claims were directed to an abstract idea and thus ineligible.
- Contour appealed.

## Issues

1. Whether the asserted claims are patent-eligible subject matter under 35 U.S.C. § 101 under the Alice two-step framework.
2. At Alice step one, whether the claims are directed to an abstract idea (such as transmitting or displaying video) or to a specific technological improvement in POV camera systems.
3. If the claims are directed to an abstract idea, whether they contain an inventive concept at Alice step two based on the ordered combination of claim elements.

## Decision

- The Federal Circuit reversed the summary judgment of ineligibility and remanded.
- The court held the asserted claims patent-eligible because they are directed to a specific technological improvement in POV camera functionality: parallel recording/streaming of multiple video streams to permit real-time remote viewing and control while preserving high-quality stored video.
- The court emphasized that the claims recited a concrete functional arrangement (different-quality streams with different handling and purposes), not merely a desired result.
- The court indicated that even if analyzed at Alice step two, the claims’ ordered combination could supply an inventive concept because of the unconventional functional interplay of known components.

## Legal Principles

- Under § 101 and Alice step one, claims are more likely eligible when they focus on a specific technological solution that improves device functionality, rather than reciting an abstract idea performed with generic technology.
- Claim eligibility may turn on whether the claims specify a particular architecture or operational requirements (how the system achieves the result), as opposed to result-only claiming.
- At Alice step two, even when individual components are known, an inventive concept can be found in an unconventional ordered combination and functional interaction among those components.
- Eligibility analysis considers the claims as a whole, including how claimed elements cooperate to address a technological problem in the relevant field.

## Conclusion

The Federal Circuit held that Contour’s POV camera claims are patent-eligible under § 101 because they target a concrete improvement—parallel generation and differentiated handling of multiple video streams enabling real-time remote preview/control without sacrificing high-quality recording—and it reversed the district court’s ineligibility judgment and remanded for further proceedings.


Contour IP Holding LLC v. GoPro, Inc., 113 F.4th 1373 (Fed. Cir. 2024)