Water Treatment Patent Invalid Under 35 U.S.C. § 101

The court granted defendant's motion for summary judgment that plaintiff's water treatment patent was invalid for lack of patentable subject matter and found that the claims were directed to an abstract idea. "[A]t bottom, the claims cover the general process of observing, analyzing, monitoring, and alerting that can be done entirely by the human mind and by using pen and paper. . . . [Plaintiff] argues that Defendants failed to consider the [patent-in-suit’s] claim limitations, including the system’s use of hardware and software to predict future events. But even with those limitations, the claims still only describe the abstract idea of collecting data, monitoring the data, processing results, and alerting the user of the results."

Neochloris, Inc. v. Emerson Process Management Power & Water Solutions, Inc. et al, 1-14-cv-09680 (ILND October 13, 2015, Order) (Chang, J.)