AI Visualize, Inc. accused Nuance Communications, Inc. and Mach7 Technologies, Inc. of patent infringement in the District of Delaware. The patents in question concerned the visualization of medical scans, with an emphasis on three-dimensional views via a low-bandwidth web portal. Nuance and Mach7 sought dismissal of the case on the grounds that the patents were directed to patent-ineligible subject matter under 35 U.S.C. § 101. The district court agreed, ruling that the patents were directed to an abstract idea and failed to provide an inventive step that transformed the abstract idea into patent-eligible subject matter. Consequently, AI Visualize’s case was dismissed.
Prior to this, the district court had granted Nuance and Mach7's motion to dismiss AI Visualize's complaint for failing to state a claim. AI Visualize then filed an amended complaint, which Nuance and Mach7 again moved to dismiss. The district court found that the patents attempted to address prior art problems with transporting large volume visualization datasets over a standard internet connection. However, the court ruled that the focus of the claimed advance over the prior art was abstract, and AI Visualize’s arguments that the claims were directed to improvements in computer functionality were rejected.
On appeal, the United States Court of Appeals for the Federal Circuit affirmed the district court’s decision. The appellate court agreed that the patents in question were directed to an abstract idea and did not offer an inventive step that transformed the idea into patent-eligible subject matter. Further, the court observed that AI Visualize's amended complaint failed to provide sufficient factual allegations to support that the claims involved unconventional technology or a concrete application of the abstract idea of virtual view "creation". Thus, the dismissal of AI Visualize’s case was affirmed.
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