Fuzzysharp Techs., Inc. v. Intel Corp.

A patent is invalid for claiming ineligible subject matter where the patent claims an abstract idea and then requires the use of conventional post-solution actives that are not varied by the output of the abstract idea.

Opinion (Rogers): Fuzzysharp Techs., Inc. ("Fuzzysharp") owns two patents claiming a method for reducing computations in three dimensional graphics processing by determining the visibility of a surface. Fuzzysharp sued Intel Corp. ("Intel") alleging Intel’s HD Graphic Code “Sandy Bridge” infringed its patents. Intel moved for judgment on the pleadings, arguing the patents covered unpatentable subject matter because they claimed abstract ideas. The district court converted Intel’s motion into a motion for summary judgment. The district court construed the claims to require determining whether an object’s surface was completely visible, completely hidden, or partial hidden and partial visible. It then considered Intel’s motion for summary judgment. Whether a patent claim is patent eligible is a question of law. Abstract concepts are not eligible for patent protection. Use of an abstract idea within a limited, practical application where the result of the abstract idea affects the post-solution activity is patent eligible, while claiming an abstract idea and stating that it has application in conventional post-solution activity is not. The court found that Fuzzysharp’s patents covered the entire field of graphics processing and that they were not limited to a specific application or inventive concept. Similarly, the court found that the patents only claimed the determination of the parts of a visibility computation that could be omitted, without altering the rendering process of the parts that were not omitted. Because the post-solution process was not changed by the output of the claimed steps, the court held that the patents did not claim an inventive concept and it, therefore, GRANTED Intel’s motion for summary judgment.