Spireon, Inc. v. Procon Analytics, LLC

This case relates to a new inventive method for vehicles. Despite the invention here improving both the functioning of (i) vehicles and (ii) “location devices” used for tracking vehicles, the district court below found the patent-in-suit invalid as an “abstract idea” under 35 U.S.C. § 101, without factual development, on a motion for judgment on the pleadings, and the Federal Circuit affirmed without opinion. The questions presented, identical to those in American Axle & Mfg, Inc. v. Neapco Holdings LLC, No. 20–891, are:

1. What is the appropriate standard for determining whether a patent claim is “directed to” a patentineligible concept under step 1 of the Court’s two-step framework for determining whether an invention is eligible for patenting under 35 U.S.C. § 101?

2. Is patent eligibility (at each step of the Court’s two-step framework) a question of law for the court based on the scope of the claims or a question of fact for the jury based on the state of the art at the time of the patent? (i)