Patent Claiming Method for Selecting Color for Digital Image Invalid Under 35 U.S.C. § 101

The court granted defendants' motion to dismiss because the asserted claims of plaintiff’s digital color selection patent encompassed unpatentable subject matter and found that the claims were directed toward a mathematical algorithm. "[The patent-in-suit] is directed to a method of selecting a color for a portion of a digital image by calculating and comparing various vectors within a specific region of space, known as a 'steradian.' . . . [Defendants] contend that the steps of claim 1 only explain how to calculate two vectors, calculate a steradian region, determine whether those vectors are located in that steradian region, compare the length of the vectors and then use that information to derive color information for the two vectors. . . . Plaintiff goes to great lengths to argue that '[s]pace is not abstract,' but is instead 'a region, and real object, we all exist in.' Plaintiff relies on the contentions that space 'exists literally' and that the computer calculations in claim 1 'bring[ ] a particular steradian . . . into existence' to support his assertion that claim 1 is directed to 'Real Objects' rather than to an abstract idea. The critical flaw with this argument, however, is that the [patent-in-suit] does not claim 'space.' Instead, it claims methods of calculating a region of space and comparing various calculations to choose a pixel color."

Coffelt, Jr. v. NVIDIA Corporation et al, 5-16-cv-00457 (CACD June 21, 2016, Order) (Otero, J.)