Contour IP Holding LLC v. GoPro, Inc

Authored by: Jeremy J. Gustrowsky

In a significant decision for technology innovators, the Federal Circuit reversed a lower court’s ruling that had invalidated Contour IP Holding LLC’s patents covering point-of-view (POV) action cameras, including U.S. Patent Nos. 8,890,954 and 8,896,694. Contour had accused GoPro, Inc. of infringing these patents, which describe a portable camera system capable of streaming a lower-quality video to a remote device (like a smartphone) for real-time viewing and control, while simultaneously recording a higher-quality version for later use.

The dispute centered on whether Contour’s patent claims were directed to an “abstract idea” and thus ineligible for patent protection under Section 101 of the Patent Act. The district court had sided with GoPro, finding the claims too abstract, but the Federal Circuit disagreed. The appellate court emphasized that the claims were not just about the general idea of streaming video or remote control, but rather about a specific technological improvement: recording two video streams in parallel and wirelessly transmitting only the lower-quality stream for real-time monitoring and adjustment.

Importantly, the court noted that the patent claims required a particular method—parallel recording of high- and low-quality streams, with only the low-quality stream sent wirelessly to a remote device. This approach solved a real technical problem: how to let users see and control what their action camera is recording in real time, even when bandwidth is limited, without sacrificing the quality of the final recording. The court found that this was a concrete technological solution, not just an abstract idea.

As a result, the Federal Circuit reversed the district court’s decision and sent the case back for further proceedings, allowing Contour’s patent claims to stand. This decision highlights the importance of clearly describing how a patent claim provides a specific technological improvement, especially in fields where software and hardware interact.