The claims of a patent for an inertial tracking system for tracking the motion of an object relative to a moving reference frame were not directed to an abstract idea, according to the U.S. Court of Appeals for the Federal Circuit. Although the claims required the use of mathematical equations, they were not directed to the equations themselves, but rather to an unconventional application of sensors that made use of the equations. A decision of the U.S. Court of Federal Claims holding that asserted claims of the patent were directed to patent-ineligible subject matter was reversed. The case was remanded for further proceedings in connection with the patent holder’s infringement claims against the federal government over a helmet-mounted display system used in F-35 jet fighters (Thales Visionix v. United States, March 8, 2017, Moore, K.).
Thales Visionix Inc. ("TVI") owned U.S. Patent No. 6,474,159 ("the ’159 patent"). The patented invention used inertial sensors—such as accelerometers and gyroscopes—to measure the specific forces associated with changes in a sensor’s position and orientation relative to a known starting position. The sensors were used in aircraft navigation and virtual reality simulations, among other applications. The inertial sensors disclosed in the ’159 patent did not use the conventional approach of measuring inertial changes with respect to the earth; instead, sensors mounted on a moving platform (or vehicle) directly measured the gravitational field in the platform frame. Sensors mounted in an object (such as a pilot’s helmet) then calculated position information relative to the frame of the moving platform. Therefore, the position and orientation of the object within the moving platform could be tracked without input from a vehicle attitude reference system or calculating the orientation or position of the moving platform itself.
TVI sued the government and asserted that the helmet-mounted display system (HMDS) in the F-35 infringed a number of claims of the ’159 patent. The government subcontractor that made the HMDS—Elbit Systems of America—joined the case as a third-party defendant. The government and Elbit moved for judgment on the pleadings, asserting that the patent’s claims disclosed ineligible subject matter under 35 U.S.C. §101 because they disclosed a law of nature. The Court of Claims granted the motion, finding that the claims: (1) were directed to the abstract idea of using laws of nature governing motion to track two objects; and (2) provided no inventive concept beyond the abstract idea. TVI appealed.
Reviewing the question de novo, the Federal Circuit held that the ’159 patent claims at issue were not directed to an abstract idea. The claims were not merely directed to the abstract idea of using "mathematical equations for determining the relative position of a moving object to a moving reference frame"; rather, they were directed to systems and methods that used inertial sensors in a non-conventional manner to reduce errors in measuring the relative position and orientation of a moving object on a moving reference frame. The claims specified a particular configuration of inertial sensors and a particular method of using the raw data from the sensors in order to more accurately calculate the position and orientation of an object on a moving platform. Although mathematical equations were required, the equations were a consequence of the arrangement of the sensors and the unconventional choice of reference frame in order to calculate position and orientation. The claims were not for the equations themselves; rather, the claims sought to protect only the application of physics to the unconventional configuration of sensors as disclosed. The court noted that the ’159 patent claims provided a method that improved accuracy over previous systems, as well as a system that was beneficially self-contained, compared to the prior solutions. Therefore, the claims were not directed to ineligible subject matter.
Because the court found that the claims were not directed to an abstract idea, it did not consider whether the claims included an additional "inventive concept."
The case is No. 2015-5150.
Attorneys: Meredith Martin Addy (Tabet DiVito & Rothstein, LLC) for Thales Visionix Inc. Andrew Paul Zager, Commercial Litigation Branch, Civil Division, United States Department of Justice, for the United States. Kurt Calia (Covington & Burling LLP) for Elbit Systems of America, LLC.
Companies: Thales Visionix Inc.; Elbit Systems of America, LLC
MainStory: TopStory Patent FedCirNews
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