TJTM Technologies, LLC v. Google LLC

TJTM Technologies, LLC v. Google LLC Representative claim 1 of U.S. Patent No. 8,958,853 is directed to the abstract idea of 'screening notifications' and recites only generic, well-known components arranged in a conventional manner, failing both steps of the Alice framework. The Federal Circuit affirmed dismissal under § 101. Confirms that adding a user-benefit feature (auto-suppressing phone notifications when paired with a vehicle) to generic mobile hardware does not constitute a technological improvement sufficient to survive § 101 at the pleading stage, and that conclusory inventive-concept allegations cannot defeat a Rule 12(b)(6) motion. Affirmed The '853 patent claims a mobile device that automatically enters 'inactive mode'—suppressing notifications and sending an away message—when paired with a vehicle; the district court and Federal Circuit both characterized this as the abstract idea of 'screening notifications.' Under Alice step one, the court rejected TJTM's analogy to Contour IP and Enfish, holding that improving user experience through a different operational mode does not amount to a technological improvement to the underlying mobile phone technology. Under Alice step two, the court found all claim components (wireless communication module, processor, memory, GUI, away message) generic and well-known, combined in conventional fashion; TJTM's amended complaint offered only conclusory assertions of an inventive concept. At oral argument, TJTM effectively conceded that Bluetooth-style device pairing was known in the field and was not itself an inventive aspect of the claims, undermining its primary step-two argument. This is a nonprecedential opinion, but it reinforces existing Federal Circuit doctrine—drawn from Trinity Info Media and Cellspin—that conclusory pleading allegations cannot rescue an abstract-idea claim from § 101 dismissal. § 101 claim construction infringement non-precedential § 101 infringement non-precedential § 101 non-precedential