CAFC Rejects Method for Manufacturing Propshafts Under 101; Judge Moore Calls Majority Analysis ‘Validity Goulash’

The U.S. Court of Appeals for the Federal Circuit (CAFC) issued a precedential opinion on October 3 involving a patent infringement suit brought by American Axle & Manufacturing, Inc. (AAM) against Neapco Drivelines LLC (Neapco) in 2015. The suit involved alleged infringement of U.S. Patent No. 7,774,911 (the ‘911 patent). The opinion, authored by Judge Dyk, affirmed the U.S. District Court for the District of Delaware’s finding that the asserted claims are ineligible under Section 101. Judge Moore dissented, saying that “the majority’s decision expands § 101 well beyond its statutory gate-keeping function and the role of this appellate court well beyond its authority.” The ‘911 patent teaches a method for manufacturing driveline propeller shafts that are designed to attenuate vibrations transmitted through a shaft assembly.After a thorough analysis of the first prong of the Alice and Mayo two-step process, the CAFC turned to the second prong and found that no inventive concept existed that could transform the claims into patent eligible subject matter. Judge Kimberly Moore filed a scathing dissent in which she said the majority opinion “deeply trouble[s]” her and that the Court’s opinion conflates Section 101 with Section 112.

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