SZ DJI Technology Co., Ltd. et al v. Yuneec International Co. Ltd. et al, 5-16-cv-00595 (CACD October 13, 2016, Order) (O'Connell, USDJ)
Monday, October 17, 2016
Drone Target Tracking Patent Not Ineligible Under 35 U.S.C. § 101
The court denied defendant's motion to dismiss on the ground that plaintiff’s drone target tracking patent encompassed unpatentable subject matter because the asserted claims were not directed toward an abstract idea. "The asserted dependent claims include additional physical limitations. For example, Claim 6 discloses [an Unmanned Aerial Vehicle] with a 'plurality of rotors,' which is a physical component of the UAV, serving the function of 'generat[ing] lift.' Claim 7 discloses an imaging device coupled to the UAV, which is again a physical relationship between tangible components. These tangible claim elements suggest that the focus of the claims addresses more than just the abstract idea of automatic target tracking. . . . [Defendant's] characterization of the invention as 'automatic tracking of a target' also ignores the stated purpose of the invention, which is to provide solutions to several problems faced specifically in UAV technology. . . . [T]he claims at issue are not directed to an abstract idea within the meaning of [Alice Corp. Pty. Ltd. v. CLS Bank Int’l, 134 S. Ct. 2347 (2014)]. Rather, they are directed to specific improvements to the way UAVs can be operated to navigate under certain circumstances and to track targets."