East Coast Sheet Metal Fabricating Corp. d/b/a EastCoast CAD/CAM v. Autodesk, Inc., 1-12-cv-00517 (NHD January 15, 2015, Order) (McCafferty, J.)
Wednesday, January 21, 2015
CAD/CAM Data Importation Patents Invalid Under Alice
The court granted defendant's motion for summary judgment that plaintiff's CAD/CAM data importation patents were invalid for lack of patentable subject matter and found that the claims were directed to the abstract idea of mapping without an inventive concept. "[A]n inventive concept is, among other things, a new idea that solves a recognized problem in a particular field of endeavor. . . . Moreover, the inventive concepts in [earlier decisions] each involved an innovation that allowed a user of the invention to achieve a better result, rather than a result that was achieved more quickly due to the replacement of direct human activity with a computer. . . . Without a disclosure of how the invention does what it does, neither the specification nor the claim identifies an inventive concept. Rather, the patent merely recites the use of a generic computer to perform generic computer operations, and that is not enough to establish an inventive concept."