Image Scanning Patent Not Invalid Under 35 U.S.C. § 101

The court denied defendant's motion for summary judgment that plaintiffs' image scanning patent was invalid for lack of patentable subject matter and found that the claims were not directed toward a patent-ineligible concept. "[Defendant] argues that 'the [patent-in-suit] is drawn to the idea of extracting digital data at a purportedly improved scan rate by implementing a mathematical relationship on a conventional scanner.' [Plaintiff] responds that the asserted claims are directed to the internal operation of a particular physical device (a scanner), with particular physical components (image sensors and motors), using signals having a particular timing relationship that differs from the prior art. The asserted claims describe steps including determining the parameters (which meet a certain mathematical formula) and applying parameters to operate a scanner. The court concludes that such claims do not claim the mathematical formula nor do they seek to simply 'implement' such a formula, therefore, the claims are not directed to an abstract idea."

Intellectual Ventures I LLC et al v. Canon Inc. et al, 1-13-cv-00473 (DED November 9, 2015, Order) (Robinson, J.)