Audio MPEG, Inc. et al v. HP Inc., 2-15-cv-00073 (VAED July 1, 2016, Order) (Morgan, J.)
Wednesday, July 6, 2016
Audio Compression Patents Not Invalid Under 35 U.S.C. § 101
The court denied defendant's motion to dismiss on the ground that plaintiffs’ audio compression patents encompassed unpatentable subject matter and rejected defendant's argument that the claims were directed toward an abstract idea. "[T]he invention's ability to run on a general-purpose computer does not doom the claims. Indeed, the claims at issue here undoubtedly make computers more efficient. They solve a problem that the MPEG Audio standards-setting organization identified. They use 'a particular frame format or intensity stereo coding to make the audio processing of [defendant's] computers far more efficient.'. . . Unlike the claims in [another case], which dealt with a way to organize images - something humans can accomplish without a computer - the claims here 'encode[ ] and decode[ ] a wide-band signal in a manner that takes into account the hearing capabilities of the human ear at different frequencies: by coding the most important frequencies as accurately as possible, and coding less critical frequencies less precisely, a realistic replica of the original signal can be reproduced with the minimal amount of data.'. . . Plaintiffs are not seeking to patent a mathematical formula or the general idea of receiving and outputting information. Thus, the Asserted Patents do not claim an abstract idea."