AMERICAN AXLE & MANUFACTURING v. NEAPCO HOLDINGS LLC
- Oct 3 2019 |
- Category: CAFC Updates
American Axle sued Neapco alleging infringement of claims of U.S. Patent No. 7,774,911 relating to a method for manufacturing propeller shafts with liners that are designed to attenuate vibrations. The parties filed cross-motions for summary judgment as to the eligibility of the asserted claims under 35 U.S.C. § 101. The district court granted Neapco’s motion and held that the asserted claims are ineligible under § 101. In an analysis of step 1 of the Mayo/Alice test, the CAFC finds that the claims of the ’911 patent are directed to the utilization of a natural law (Hooke’s law and possibly other natural laws) in a particular context, and that while the system involved in the ’911 patent is more complex than just a bare application of Hooke’s law, what is missing is any physical structure or steps for achieving the claimed result of damping two different types of vibrations. As to Mayo/Alice step 2, the CAFC finds that nothing in the claims qualifies as an “inventive concept” to transform the claims into patent eligible matter. The CAFC therefore affirms. Judge Moore dissents because in his view the majority’s decision reduces the Alice/Mayo two-part test to a single inquiry: If the claims are directed to a law of nature then the claims are ineligible and all evidence of non-conventionality will be disregarded or just plain ignored.