District Court Dismissed Claim Directed to Natural Speech Processing in a Vehicle-Mounted System as Patent Ineligible

November 21, 2023District Court, Patent Litigation, Patent-Ineligible Abstract Ideas

The Eastern District of Virginia recently dismissed a patent infringement claim, holding that the asserted claim directed to natural speech processing is patent ineligible under 35 U.S.C. § 101, because it fails the Alice framework. Under step one, the court found the claim is directed to an abstract idea, because it is “plainly result-oriented” and “directed to any arrangement of programs and processors.” Under step two, the court found the claim lacks an inventive concept, because it does not explain how its “conclusory, result-oriented requirements” overcome the defects in prior art.

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