In Thales Visionix Inc., v. United States, Appeal No. 2015-5150, the Federal Circuit found claims directed to an inertial tracking system patent eligible under step one of the Alice analysis because the claims sought to protect the application of physics to an unconventional configuration of inertial sensors
Thales claimed an inertial tracking system for tracking the motion of an object relative to a moving reference frame. The invention disclosed a configuration in which the object’s inertial sensors calculate position relative to the frame of the moving platform itself, thereby requiring fewer measured inputs and reducing calculation error. TVI sued the United States and asserted that the helmet-mounted display system in F-35 jets infringes its claims. On a motion for judgment on the pleadings, the Court of Federal Claims found the patent claims invalid under Section 101. Thales appealed.
The United States argued that the claims were directed to patent-ineligible subject matter under 35 U.S.C. 101 because they are (1) directed to the abstract idea of using laws of nature governing motion tracking two objects, and (2) provide no inventive concept beyond the abstract idea. The Federal Circuit rejected those arguments. The court found the claims at issue nearly indistinguishable from Diehr. In Diehr, the rubber-curing method improvements were based on a well-known mathematical equation to reduce production errors. Here, the claimed invention was also utilizing mathematical equations to reduce errors. Considering the invention as a whole and noting multiple advantages of the claimed system, such as increased accuracy, simpler hardware, and easier installation, the Court found the claims were more than merely directed to an abstract idea. Finding the mathematical equations to be only a consequence of the arrangement of the sensors and the unconventional choice of reference frame, the court found that the claims were seeking to protect the application of physics to the unconventional configuration of sensors as disclosed.