France Telecom S.A. v. Marvell Semiconductor, Inc., 3-12-cv-04967 (CAND April 14, 2014, Order) (Orrick, J.)
Wednesday, April 16, 2014
Turbo Coding Patent Not Invalid for Claiming Unpatentable Subject Matter
The court denied defendant's motion for summary judgment that plaintiff's turbo coding telecommunications patent was invalid for claiming unpatentable subject matter. "[Defendant] argues that Claims 1 and 10 do not meet the transformation prong of the MOT test because the 'mere manipulation of data' is insufficient to do so. . . . To characterize the methods disclosed in Claims 1 and 10 as 'calculations' based on well-known formulae misunderstands the fact that the claims in the [patent] are 'inventive application[s] of [ ] principle[s that] may be patented.' The claims explain how to perform a particular method of error correction and decoding -- they do not simply identify an abstract idea and instruct the reader to apply the idea. . . . the purpose of the [patent-in-suit] is to disclose a method for more accurate and efficient data transmission. . . . [The challenged claims] meet the eligibility standard under the patent laws."