By: Mel R. Quintos

In the case of Vehicle Intelligence v. Mercedes-Benz USA, LLC, decided upon by the U.S. Court of Appeal for the Federal Circuit (CAFC) on December 28, 2015, the district court determined, and the parties agreed, that the claims at issue in U.S. Patent No. 7,394,392, owned by Vehicle Intelligence, fall within the broad categories of patentable subject matter under 35 U.S.C. §101 (i.e., “any new and useful process, machine, manufacture, or composition of matter, or any new and useful improvement thereof”).

On appeal, however, the CAFC must determine whether the district court was correct in deciding that the claims at issue do not fall into the judicially created exception of patent-ineligible abstract ideas and are therefore invalid as drawn to patent-ineligible subject matter under 35 U.S.C. §101. In doing so, the CAFC applied the following 2 Step Test introduced in the U.S. Supreme Court case of Mayo Collaborative Services v. Prometheus Laboratories, Inc. and further explained in yet another U.S. Supreme Court case, Alice Corp. Party v. CLS Bank International: —click here to read more—