Capstan AG Systems, Inc. v. Raven Industries, Inc. et al, 5-16-cv-04132 (KSD January 11, 2017, Order) (Crabtree, USDJ)
Friday, January 13, 2017
Step One of Alice Analysis Not Limited to Patent’s Novel Claims
The court denied defendants' motion to dismiss on the ground that plaintiff’s agrochemical spraying system patents encompassed unpatentable subject matter and rejected defendants' argument that the court must focus its analysis of step one in Alice Corp. v. CLS Bank Int’l, 134 S. Ct. 2347 (2014) to the novel claims of the patents-in-suit. "Defendants contend that the Federal Circuit’s admonition to consider the focus of the patents’ claimed advance over the prior art requires the court to narrow its Alice step-one inquiry to the [patents-in-suit’s] novel claims. The court disagrees. To adopt defendants’ method would require the court to import the novelty inquiry found under § 102 into the § 101 analysis. The Supreme Court has rejected this method many times. . . . In step one of the Alice test, the court simply considers the patent’s claims as a whole to determine what their focus is."