Wavetronix LLC v. Iteris, Inc., 1-14-cv-00970 (TXWD January 22, 2015, Order) (Sparks, J.)
Monday, January 26, 2015
Patent Employing Mathematical Formula for Real-Time Traffic Tracking Not Invalid Under Alice
The court denied without prejudice plaintiff's motion for a preliminary injunction precluding the sales of defendant's traffic sensor products, but rejected defendant's argument regarding lack of patentable subject matter. "Claiming the [patent-in-suit] is . . . directed at an abstract process generically implemented, [defendant] contends 'a human with no more than a high-school level education can readily accomplish each of the steps taught [by the patent-in-suit] with nothing more than a paper and a pencil.' The Court disagrees, and is unpersuaded [Alice Corporation v. CLS Bank International, 134 S. Ct. 2347 (2014)] is applicable to this case. Merely employing a mathematical formula does not render a claimed method unpatentable where the method improves upon an existing technological process, and the evidence presently before the Court indicates the [patent-in-suit] significantly improved upon existing technological processes for providing dilemma zone protection. Some previous purported solutions, for example, were based upon virtual loops or physical loops buried in the ground, and did not really solve the problem. . . . [Plaintiff] improved upon those solutions by devising a process which by making use of a mathematical formula enables accurate real-time tracking of vehicles as they approach an intersection."