Thales Visionix Inc. v. United States
850 F.3d 1343
| Fed. Cir. | 2017Background
- Thales Visionix, Inc. (TVI) owns U.S. Patent No. 6,474,159 claiming systems and methods for tracking an object's orientation and position relative to a moving reference frame using two inertial sensors (one on the object, one on the platform).
- The patented technique places and uses inertial sensors in an unconventional reference frame (platform frame) so platform sensors measure gravitational effects in that frame and object sensors compute orientation relative to the platform, reducing error and obviating external attitude data.
- TVI sued the United States alleging the F-35 helmet-mounted display system (HMDS) infringed multiple claims of the ’159 patent; Elbit (subcontractor) joined as third-party defendant.
- The government and Elbit moved for judgment on the pleadings under 35 U.S.C. § 101, arguing the asserted claims claim patent-ineligible subject matter (laws of nature/abstract idea).
- The U.S. Court of Federal Claims granted the motion, holding the claims directed to an abstract idea and lacking an inventive concept; TVI appealed to the Federal Circuit.
- The Federal Circuit reversed, holding the claims are not directed to an abstract idea because they recite a specific sensor configuration and method application that improves inertial tracking accuracy.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether asserted claims of the ’159 patent are directed to patent-ineligible subject matter under § 101 | TVI: Claims recite a specific, unconventional sensor configuration and method that improves tracking accuracy and are patent-eligible. | Government/Elbit: Claims are directed to laws of nature/mathematical equations (an abstract idea) and lack an inventive concept. | Reversed: Claims are not directed to an abstract idea; they recite a specific application/configuration and survive Alice step one. |
Key Cases Cited
- Gottschalk v. Benson, 409 U.S. 63 (Sup. Ct.) (basic tools of scientific work are not patentable)
- Diamond v. Diehr, 450 U.S. 175 (Sup. Ct.) (application of a mathematical formula within an improved industrial process is patent-eligible)
- Mayo Collaborative Servs. v. Prometheus Labs., Inc., 566 U.S. 66 (Sup. Ct.) (laws of nature and natural correlations are not patentable)
- Alice Corp. Pty. v. CLS Bank Int’l, 134 S. Ct. 2347 (Sup. Ct.) (two-step framework for patent-eligibility analysis)
- Enfish, LLC v. Microsoft Corp., 822 F.3d 1327 (Fed. Cir.) (claims directed to a specific improvement in computer functionality are patent-eligible)
- Rapid Litig. Mgmt. Ltd. v. CellzDirect, Inc., 827 F.3d 1042 (Fed. Cir.) (claims applying a natural discovery in a new laboratory technique are patent-eligible)
- Elec. Power Grp., LLC v. Alstom S.A., 830 F.3d 1350 (Fed. Cir.) (step one can end § 101 inquiry when claims are directed to an abstract idea)