Claims of U.S. Patent Nos. 5,323,396, 5,777,992, and 5,539,829, directed to audio encoding techniques for the MPEG standard, survived a patent-eligibility challenge under 35 U.S.C. § 101 after the court, favorably comparing the patents’ claims to those in Enfish LLC v. Microsoft Corp., found that the claims were not abstract. Audio MPEG Inc. v. Dell Inc., No. 16-cv-00082 (E.D. Va. July 1, 2016).
The heart of the court’s analysis is not lengthy, and is self-explanatory:
Here, as in Enfish, the invention’s ability to run on a general purpose computer does not doom the claims. Indeed, the claims at issue here undoubtedly make computers more efficient. They solve a problem that the MPEG Audio standards-setting organization identified. They use “a particular frame format (“396, ‘992) or intensity stereo coding (‘829) to make the audio processing of Dell computers far more efficient.” The claims are “directed to specific equipment that encodes and decodes digital audio in a new way, using a specific format that is more efficient and flexible than previous methods to solve an existing problem.” Unlike the claims in TLI, which dealt with a way to organize images – something humans can accomplish without a computer – the claims here “encode and decode a wide-band signal in a manner that takes into account the hearing capabilities of the human car at different frequencies: by coding the most important frequencies as accurately as possible, and coding less critical frequencies less precisely, a realistic replica of the original signal can be reproduced with the minimal amount of data.” The claims thus resemble those at issue in Enfish. Plaintiffs are not seeking to patent a mathematical formula or the general idea of receiving and outputting information. Thus. the Asserted Patents do not claim an abstract idea. Hence, the patents claim eligible subject matter under 35 U.S.C. § 101. Because the Asserted Patents are directed to patent-eligible concepts, there is no need for the Court to address the second step of Alice. See, e.g., Enfish.