By Linda O’Brien, J.D., LL.M.
Four patents pertaining to registering and displaying video images in a heads up display were not directed to a patent-ineligible concept as the asserted claims provided a particular solution to an industry issue and deployed an unconventional technique, the U.S. Court of Federal Claims has held. Thus, a motion by the U.S. government to dismiss for failure to state a claim was denied (Science Applications International Corp. v. U.S., January 19, 2018, Bruggink, E.).
On January 19, 2018, Science Applications International Corporation (SAIC), a scientific, engineering, and technology applications company, filed suit against the U.S. government, claiming infringement of four patents relating to technology for specialized heads up displays (HUDs) and night vision goggles, after the government entered into procurement contracts with a SAIC competitor. The four asserted patents were U.S. Patent Nos. 7,787,012 ("the ‘012 Patent"), 8,817,103 ("the ‘103 Patent"), 9,229,230 ("the ‘230 Patent"), and 9,618,752 ("the ‘752 Patent"). The ‘012 Patent and ‘103 Patent are both entitled "System and Method for Video Image Registration in a Heads Up Display." The ‘230 Patent and ‘752 Patent are both entitled "System and Method for Video Image Registration and/or Providing Supplemental Data in a Heads Up Display."
SAIC argued that its patents claim methods and systems of accurately positioning images from two independently movable sources by using orientation and motion sensors and data in an unconventional way. The government contended that SAIC’s patents claim the abstract idea of superimposing a video image in a location on a display as to preempt future innovation in how images can be manipulated to appear in the same field of vision.
The court found that, based on the face of the asserted claims and the specifications, the plaintiff’s patents combined existing computer technology, sensors, and calculations in an unconventional way to reach a solution for achieving accuracy and consistency in image registration and, therefore, were not directed to an abstract idea.
The government’s argument that the patent claims were directed to the abstract idea of superimposing video images based on relative orientation and motion data was rejected. First, the patent claims offered advances over the prior art of registering images by detecting orientation of a video and display that were independently moveable in order to register images within accurate boundaries. Although the claims involved patent-ineligible calculations of the laws of nature governing motion, they constituted an improvement over prior approaches and were limited to patenting a particular way to measure relative position and orientation, the court explained.
Second, the claims were directed to improving the prior process by using known components in an unconventional way to register images within accurate boundaries and anticipate the use of independently movable image sources such that the orientation sensing and boundary recognition process was continuous, according to the court. Further, the claims did not lack structure since they disclosed how to accurately identify and place images by specifically using orientation sensors or motion data to allow a computer to identify, compare, and adjust images that were more concrete than the general dissemination of content through a downloadable application.
The government’s contention that the plaintiff’s claimed methods could be performed with just the human eye and a weapon scope also was rejected. The court noted that, although the human mind was capable of matching images and evaluating differences, the patent claims recited a means of automatically and continuously performing the evaluation without the user needing to adjust his or her field of vision. Since SAIC provided a solution to the issue of alignment and consistently accurate display beyond the concept of superimposition, the claims were not directed to an abstract idea, the court concluded.
The case is No. 1:17-cv-00825-EGB.
Attorneys: Christopher C. Campbell (Cooley, LLP) for Science Applications International Corp. Alex Hanna, U.S. Department of Justice, for the United States.
Companies: Science Applications International Corp.
MainStory: TopStory Patent
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