No Simulating Alice Requirements: Application of Abstract Ideas Alone Cannot Transform Patent Ineligible Subject Matter
Before Prost, Clevenger, and Stoll. Appeal from the United States District Court for the District of Utah.
Summary: A claim whose only inventive concept is the applications of an abstract idea using conventional and well-understood techniques is not sufficient to transform the claim into a patent-eligible idea.
Simio sued FlexSim Software Products (“FlexSim”) for infringing its patent directed to creating object-oriented simulations using graphics instead of coding to allow the user to more easily build the simulations. FlexSim moved to dismiss the complaint for failure to state a claim, arguing that Simio’s asserted claims were abstract ideas that were ineligible for patenting under § 101. The District Court dismissed the complaint, finding that Simio’s claims were not patent eligible under Alice’s two-step framework. Simio then filed a motion for reconsideration, which the District Court denied. Simio appealed.
The Federal Circuit affirmed, holding that the claims were directed to patent ineligible subject matter. The Federal Circuit agreed that the claims were directed to the abstract idea of using graphics instead of programming to create object-oriented simulations, which had been used since the 1980s and 1990s. The Federal Circuit disagreed with Simio that the asserted claims improve the functionality of prior simulations because the claims improve the user experience, not the functionality of the computer itself. The Federal Circuit also held that the claims did not transform the abstract idea into patent-eligible inventions because the claims lacked any inventive concept or meaningful application of the abstract idea to save the claims. Thus, the claims were patent-ineligible.
Editor: Paul Stewart