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Coffelt v. Nvidia Corp.

Representative Claim

1.  A method for deriving a pixel color comprising the steps of:

a computer calculating a first position vector for a geometric graphic object;
a computer calculating a particular steradian region of space;
a computer calculating a particular steradian radius of said steradian region of space;
a computer calculating that said first position vector is located in said particular steradian region of space;
a computer calculating a second position vector for a geometric graphic object;
a computer calculating that said second position vector is located in said particular steradian region of space;
a computer calculating a length of said first position vector;
a computer calculating a length of said second position vector;
a computer comparing said first length to said second length;
for a first pixel, a computer deriving a pixel color for said first position vector from a result of said length comparison;
for a second pixel, a computer deriving a pixel color for said second position vector from a result of said length comparison.

Posture:

Appeal from United States District Court for the Central District of California (Case No.: 5:16-cv-00457)

Abstract Idea: Yes

At the first step of the Alice/Mayo framework, the court found that the claims on appeal are directed to “the abstract idea of calculating and comparing regions in space,” characterizing the claimed subject matter as “a purely arithmetic exercise” that “could be implemented using a pen and paper.”  In support of this conclusion, the court referenced its prior holding that “‘analyzing information by steps people [can] go through in their minds, or by mathematical algorithms, without more . . . [are] mental processes within the abstract-idea category.’ Synopsys, Inc. v. Mentor Graphics Corp., 839 F.3d 1138, 1146 (Fed. Cir. 2016).”

Something More: No

At step two of the Alice/Mayo framework, the court relied primarily on the fact that the claimed algorithm “can be implemented on a generic computer.”  The court rejected arguments from the appellant/patent owner that the claimed algorithm was an improvement on the prior art because:
“The novelty of the algorithm . . . does not determine whether the claim recites an inventive concept. Instead, the inventive concept must ‘transform’ the patent-ineligible algorithm into a ‘patent-eligible application’ of the algorithm, and do so by more than merely implementing the algorithm on a generic computer.”