Claims utilizing mathematical equations are not necessarily “doomed” as unpatentable subject matter under § 101
The patentee asserted its patent for an inertial tracking system for tracking the motion of an object relative to a moving reference frame. The Court of Federal Claims granted judgment on the pleadings for the accused infringer, finding that the patent-in-suit was directed to patent-ineligible subject matter under 35 U.S.C. § 101. On appeal, the Federal Circuit reversed and remanded.
The patent-in-suit was directed to solving the problem of tracking inertial motion of an object on a moving platform (e.g., tracking the motion of a jet taking off on an aircraft carrier). The prior art taught a two sensor system where both the object- and platform-based sensors measured motion relative to the earth, and error-correcting sensors measured position relative to the platform. The patent-in-suit claimed a system that changes the reference frame—the platform sensors directly measured the gravitational field in the platform frame, and the object sensors measured motion in reference to the platform. The Court of Federal Claims found that the claims were merely directed to the abstract idea of using “mathematical equations for determining the relative position of a moving object to a moving reference claim.”
The Federal Circuit disagreed, holding that the claims were patent-eligible at step one of the Alice test. Specifically, the Federal Circuit held that the claims were not “patent-ineligible subject matter” because the claims were “direct to systems and methods that use 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.” Further, the application of physics and mathematics did not “doom the claims” under § 101 because the claims were “directed to a new and useful technique for using sensors to more efficiently track an object on a moving platform.”