Magna Electronics, Inc. v. Valeo, Incorporated, 5:13-cv-11376

Magna Electronics sued several Valeo entities alleging infringement of U.S. Patent No. 7,859,565 and U.S. Patent No. 7,877,175 (vision/object detection system patents).
Defendants moved for judgment on the pleadings under Rule 12(c), arguing the ’175 patent claims are directed to patent-ineligible subject matter under 35 U.S.C. § 101 and Alice.
The motion was referred to a Special Master, who issued a Supplemental Report recommending denial of the motion.
Valeo objected; the district court reviewed the Special Master’s report de novo for legal conclusions and adopted the report in full.
The court denied defendants’ motion without prejudice, concluding that on the present record the ’175 patent is not clearly directed to ineligible subject matter and that eligibility is best resolved alongside other patentability issues.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the ’175 patent claims are directed to patent-ineligible subject matter under §101/Alice	Magna contends the claims recite a patent-eligible technical solution for vehicle vision/object detection	Valeo contends the claims are abstract and therefore ineligible under Alice	Denied without prejudice: court adopts Special Master finding that, on the record, the ’175 patent is not shown to be ineligible and eligibility should be evaluated with other validity issues

Alice Corp. Pty. Ltd. v. CLS Bank Int’l, 573 U.S. 208 (2014) (establishes two-step framework for §101 patent-eligibility analysis)
In re TLI Commc’ns LLC Patent Litig., 823 F.3d 607 (Fed. Cir. 2016) (guidance on abstract idea analysis in §101 cases)
Bascom Global Internet Servs. v. AT&T Mobility LLC, 827 F.3d 1341 (Fed. Cir. 2016) (consideration of claim elements individually at Alice step two)
Thales Visionix Inc. v. United States, 850 F.3d 1343 (Fed. Cir. 2017) (distinguishing inventions that present technical solutions from those that are abstract)