Minitab, Inc. v. EngineRoom, LLC, 4-12-cv-02170 (PAMD February 3, 2015, Order) (Jones, J.)
Thursday, February 5, 2015
Hypothesis Testing Patent Invalid Under Alice
The court granted plaintiff's motion for summary judgment that defendant's hypothesis testing patents was invalid for lack of patentable subject matter because there was no inventive concept. "[T]he patents describe . . . 'a method of automatically applying hypothesis testing to a data set' . . . The commercial embodiment of the patents is software compatible with a personal computer and it is marketed as a business process improvement tool for users with little or no previous exposure to applied statistics. . . . [T]he limitations of the asserted claims recite only well-known, conventional activities. . . . Although certain additional limitations, such as providing descriptions and explanations 'understandable by a user unfamiliar with statistical analysis,' add some semblance of particularity . . . 'the concept embodied by the majority of the limitations describes only the abstract idea of [hypothesis testing].' The addition of detailed steps alone will not transform an abstract idea into patent-eligible subject matter."