TDE Petroleum Data Solutions, Inc. v. AKM Enterprise, Inc. d/b/a Moblize, Inc., 4-15-cv-01821 (TXSD September 11, 2015, Order) (Miller, J.)
Wednesday, September 16, 2015
Patent Directed to Determining State of Well Drilling Operations Invalid Under 35 U.S.C. § 101
The court granted defendant's motion to dismiss because plaintiff’s well state detection patent claimed unpatentable subject matter and found that the claims were directed toward an abstract idea. "[Defendant] argues . . . that Claim 1 'involves nothing more than the basic steps of (1) making a list of possible values (drilling "states"), (2) receiving data about those values, (3) applying mathematical rules to the data (by comparing data to the "limit")[,] and (4) interpreting the results to choose a value from the list.” [Defendant] . . . asserts that [plaintiff's] claimed method falls squarely within the type of data-interpretation claims that the Federal Circuit and district courts have held are abstract. . . . The steps that both [parties] contend are at the core of the [patent-in-suit] are . . . simple steps of storing data, receiving data, and using mathematics or a computer to organize that data and generate additional information. This is an abstract concept."