Fed Circuit rules American Axle & Manufacturing patent is invalid
The US Court of Appeals for the Federal Circuit has upheld a ruling that a patent owned by American Axle & Manufacturing ( AAM) is ineligible and cannot be enforced.
The precedential judgment, published yesterday, October 3, said the claims of the patent (US number 7,774,911) are simply directed to the utilisation of a natural law and do not specify how to implement an invention.
In 2015 AAM sued a competitor, Neapco, alleging that it was infringing the ‘911 patent. Neapco denied infringement and sought to have the patent revoked, a motion which was upheld by the US District Court for the District of Delaware.
The patent in dispute related to a method for manufacturing driveline propeller shafts with liners that are designed to attenuate the vibrations transmitted through the assembly of a shaft, because such vibrations cause high volumes of noise. Three types of vibrations occur during the manufacturing process.
In its ruling, the Federal Circuit referred to two prior art methods of attenuation. One of these involved the use of liners, hollow tubes made out of fibrous materials, which may dampen the vibration when inserted into the propeller shaft.
The court said other prior art methods of damping also existed, including the use of weights.
According to AAM, the claims of the ‘911 patent cover an inventive step because “unlike previous dampers and absorbers” its invention “can dampen multiple types of vibration simultaneously”.
In its judgment, the Federal Circuit upheld the district court's finding that the claims of the ‘911 patent are directed to laws of nature: Hooke’s law and friction damping.
The court said the claims of the patent were “well-understood, routine, activity already engaged in by the scientific community”.
Additionally, the Federal Circuit rejected AAM’s argument and said the ‘911 patent does not specifically claim a mechanism for dampening multiple types of vibrations simultaneously.
“Most significantly, the claims do not instruct how the variables would need to be changed to produce the multiple frequencies required to achieve a dual-damping result,” the court said.
The court cited previous case law, a US Supreme court decision in Parker v Flook, which it said reinforced its conclusion that “a claim to a natural law concept without specifying the means of how to implement the concept is ineligible”.
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