Semiconductor Memory Circuit Board Configuration Patents Not Invalid Under 35 U.S.C. § 101

The court denied defendant's motion for judgment on the pleadings on the ground that plaintiff’s semiconductor memory circuit board configuration patents encompassed unpatentable subject matter because the claims were not directed toward an abstract idea. "According to [defendant], '[p]ut simply, space optimization — the sole purported improvement claimed in the [patents-in-suit] — is a fundamental concept and is not patentable as a matter of law.' The Court, however, believes that [defendant] frames the issue too generally — the patents at issue here concern physical layouts for particular memory cards that enable the card to either have a slimmer profile or have more memory chips on it than it otherwise would have had. . . . This is not a case where an inventor is trying to get around the prohibition of patenting abstract processes by tying an abstract process such as multitasking, a computer hardware design process, or a bingo game to a generic computer setup that executes that abstract idea. Rather, the hardware configuration itself is the unique focus of the patent. . . . [Defendant] has not . . . cited any case where a court found that a claim for a purportedly novel physical configuration of a piece of computer hardware was deemed patent-ineligible because it was merely the embodiment of an abstract process."

Polaris Innovations Limited v. Kingston Technology Company, Inc., 8-16-cv-00300 (CACD July 21, 2016, Order) (Carney, J.)