The mere use of special-purpose hardware without providing implementation details is not sufficient to transform an otherwise abstract idea into patent eligible subject matter. Here, for example, although the court acknowledged that execution of a vehicle operator safety screening method using specialized equipment modules may entail hardware and software differences compared to execution on a larger generic computer, it ultimately found that this was inadequate because the specification was completely devoid of any explanation of what these hardware and software differences are, let alone any explanation as to how to implement them using existing equipment modules. “Merely stating that the methods at issue are performed on already existing vehicle equipment, without more, does not save the disputed claims from abstraction.” It may therefore be helpful for establishing subject matter eligibility to provide detailed explanations and examples of how special-purpose hardware can be configured to implement an otherwise abstract idea beyond the computational functions of more general-purpose hardware.
Background / Facts: The patent being asserted here is directed to screening vehicle operators for impairment, selectively testing those operators, and controlling vehicle equipment if an impairment is detected. The specification explains that the invention operates on “specialized existing equipment modules” such as the gas and brake pedals and the steering wheel of a car (i.e., an “equipment operations module allowing the equipment operator to control … speed of operation and direction of movement”), and stereo, navigation, anti-theft, and climate-control systems.
Issue(s): Whether the claims at issue are rendered patent-eligible by being embedded in “specialized existing equipment modules,” such as the gas and brake pedals and the steering wheel of a car, as opposed to generic computers.
Holding(s): No. “[M]arkedly absent from the [] patent is any explanation of how the methods at issue can be embedded into these existing modules.” While execution using existing equipment modules may entail hardware and software differences compared to execution in a larger generic computer, the specification “is completely devoid of any explanation of what these hardware and software differences are, let alone any explanation how to implement them using the existing equipment modules.” In particular, “the claims do not specify what screening should be done or how the expert system would perform such screening. They do not explain how to select the tests to run or even what tests to select from. They do not explain how the ‘time-sharing allocation’ on a processor should be done. And they do not explain how the expert system works to screen for impairments or how such systems can be portioned out over one or more equipment modules.” In short, “[m]erely stating that the methods at issue are performed on already existing vehicle equipment, without more, does not save the disputed claims from abstraction.”