“Without additional limitations, a process that employs mathematical algorithms to manipulate existing information to generate additional information is not patent eligible.” Tying the manipulation to an underlying data structure—even one that is technological in nature (e.g., integral to an image processing system)—is not sufficient to transform the method into patent-eligible subject matter because “[d]ata in its ethereal, non-physical form is simply information that does not fall under any of the categories of eligible subject matter under section 101.” (Although this is the first Federal Circuit opinion on subject matter eligibility following the Supreme Court’s CLS Bank v. Alice Corp. ruling, it largely sidesteps the Mayo analysis outlined there, remaking only that “[t]he Supreme Court recently reaffirmed that fundamental concepts, by themselves, are ineligible abstract ideas.”)
Background / Facts: The patent being asserted here is directed to digital image processing, and in particular, to “device profiles” that describe the color properties of both the source (e.g., digital camera) and output (e.g., printer) devices to enable a more accurate translation of an image’s pixel data. The claims at issue target both the “device profiles” themselves and methods of generating them, but focus largely on the content of the device profile data structure rather than on how device profiles are used in image processing systems.
Issue(s): Whether data structures themselves or the generation thereof are patent-eligible subject matter when they are an integral part of the design and calibration of a processor device within a technological (e.g., digital image processing) system.
Holding(s): No. The court first quickly dispatched with the direct “device profile” claims as being simply “directed to information in its non-tangible form.” Turning to the method claims, the court characterized these claims as reciting “a process of taking two data sets and combining them into a single data set, the device profile,” where the two data sets are generated simply by “taking existing information—i.e., measured chromatic stimuli, spatial stimuli, and device response characteristic functions—and organizing this information into a new form.” The court therefore concluded that these claims “recite[] an ineligible abstract process of gathering and combining data that does not require input from a physical device.” Although the court seemed to find it problematic that the patent “does not claim the processor’s use of that profile in the capturing, transforming, or rendering of a digital image,” because it found the method claims “so abstract and sweeping as to cover any and all uses of a device profile,” it concluded that it “need not decide whether tying the method to an image processor would lead us to conclude that the claims are directed to patent eligible subject matter in accordance with the Supreme Court’s Mayo test [as instructed by Alice Corp.].”