Coffelt v. NVIDIA Corporation
Case number: 16-cv-00457
United States Court of Appeal for the Federal Circuit
Decided: March 15, 2017
Editor’s Note: We apologize for not reporting on this case sooner, but for posterity, we felt it was important to include this case on our site.
Louis A. Coffelt Jr. filed suit in March 2016 against NVIDIA Corporation. Coffelt alleged that both the animation studio Pixar and software companies Autodesk Inc. and NVIDIA Corp. make software involving visual computing that infringed his patent. Coffelt owned U.S. Patent No. 8,614,710 (the ‘710 Patent), which describes a method of deriving a pixel color for a portion of a digital image. This method calculates and compares various regions of space, which are measured in “steradians.” In June 2016, the Central District of California ruled that the ‘710 Patent was invalid because it directed to an abstract algorithm of calculating and comparing vectors within a specific region in space. The district court held that because the ‘710 Patent does not go beyond implementing the aforementioned patent-ineligible algorithm on a computer, it has not sufficiently transformed into a patent-eligible invention. On March 15, 2017, the Federal Circuit affirmed the district court’s ruling that the ‘710 patent was invalid as abstract under the U.S. Supreme Court’s 2015 ruling in Alice Corp. v. CLS Bank International. The Federal Circuit’s opinion also affirmed the lower court’s holding that the claims in the patent had failed to disclose an “inventive concept” as per the Supreme Court’s ruling in Alice. In Alice, the court held that abstract ideas which are implemented through a computer are patent-ineligible under Section 101 of the Patent Act.
The Federal Circuit rejected Coffelt’s argument that the claims were patent eligible and directed to an abstract idea because “[f]irst, the claims at issue here are directed to the abstract idea of calculating and comparing regions in space,” and “[s]econd, the claims lack an inventive concept sufficient to transform the abstract idea into a patent-eligible invention.” After the ruling, the U.S. Supreme Court denied certiorari to Coffelt.
We have reported in previous cases the effect that the Supreme Court’s Alice outcome has had on computer and software patents. There are still many unanswered questions in the wake of Alice regarding subsequent applications of the case in both the courts and at the patent office.
Additional Research by: Rachel Johns
Edited By: Andrew F. Thomas