Proto Labs, Inc. v. ICO Products, LLC, 0-15-cv-02562 (MND July 13, 2016, Order) (Mayeron, M.J.)
Monday, July 18, 2016
Patents for Generating Automatic Molded Part Quotation Invalid Under 35 U.S.C. § 101
The court granted defendant's motion to dismiss because the asserted claims of plaintiff’s patents for automatically generating molded part quotations encompassed unpatentable subject matter and found that the claims lacked an inventive concept. "[T]he fact that the [patent-in-suit] manages and implements the quotation process via a computer or 'automatically,' standing alone, does not render the asserted claims patent-eligible. . . . [T]he 'invention' claimed by the [patent] is nothing more than 'a computerized method for fast identification of the mold manufacturability issues' wherein 'mold manufacturability issues are automatically identified and communicated to the customer.' However, 'relying on a computer to perform routine tasks more quickly or more accurately is insufficient to render a claim patent eligible.'. . . [T]he fact that the human mind is unable to interpret the raw bits of information contained in a CAD file is not determinative of whether the asserted claims are directed to an abstract concept. . . . [T]he use of CAD files and CAD software to convey and interpret a customer’s part design as part of the quotation process is not an inventive concept in the mold-making industry."