Coffelt v. Nvidia Corporation
680 F. App'x 1010
Fed. Cir.2017Background
- Patent owner Louis A. Coffelt, Jr. asserted U.S. Patent No. 8,614,710, directed to a method for deriving a pixel color in a graphic image (one independent claim and five dependents).
- Coffelt sued NVIDIA for patent infringement in the Central District of California.
- The district court granted NVIDIA’s motion to dismiss under 35 U.S.C. § 101, holding all claims invalid as directed to an abstract mathematical algorithm for calculating and comparing regions in space.
- The district court emphasized the claimed calculations (steradian regions, vector math) are arithmetic steps that could be performed mentally or with pen and paper.
- Coffelt appealed, arguing the claims are not abstract because they require real 3-D space and that they recite an inventive concept improving 2-D shadow-map technology to produce realistic 3-D shadows.
- The Federal Circuit affirmed, finding the claims directed to an abstract idea and lacking an inventive concept beyond a generic computer implementation.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the claims are directed to an "abstract idea" under § 101 | Coffelt: claims require real/3‑D space (steradian region), so not abstract | NVIDIA: claims recite mathematical calculations/comparisons—an abstract idea | Held: Claims directed to abstract idea of calculating/comparing regions in space (mental/mathematical process) |
| Whether the claims recite an "inventive concept" sufficient to transform the abstract idea into patent-eligible application | Coffelt: novel application/improvement over 2‑D shadow maps producing realistic 3‑D shadows is inventive | NVIDIA: novelty of an algorithm does not supply inventive concept; claims implement algorithm on generic computer | Held: No inventive concept; mere algorithm or its implementation on generic computer insufficient under Alice |
Key Cases Cited
- Synopsys, Inc. v. Mentor Graphics Corp., 839 F.3d 1138 (Fed. Cir. 2016) (analyzing mental processes and mathematical algorithms as abstract-idea category)
- Alice Corp. Pty. Ltd. v. CLS Bank Int’l, 134 S. Ct. 2347 (2014) (holding that implementing an abstract idea on a generic computer does not render it patent eligible)