Summary of Signal IP, Inc. Decisions from March 2016

Signal IP, Inc. v. American Honda Motor Co., Inc., CV 14-02454(C.D. Cal. March 22, 2016)
Signal IP, Inc. v. Nissan North America, Inc., CV 14-02962(C.D. Cal. March 22, 2016)
Signal IP, Inc. v. Mercedes-Benz USA, LLC, et al., CV 14-03109(C.D. Cal. March 22, 2016)
Signal IP, Inc. v. BMW of North America, LLC et al., CV 14-03111(C.D. Cal. March 22, 2016)
Signal IP, Inc. v. Mazda Motor of America, Inc., CV 14-00491 (C.D. Cal. March 22, 2016)

Patent(s):    

  • 5,463,374  | Entitled “Method and apparatus for tire pressure monitoring and for shared keyless entry control“
  • 5,714,927 | Entitled “Method of improving zone of coverage response of automotive radar”
  • 5,954,775 | Entitled “Dual rate communication protocol”

Disposition:               

Motion for Summary Judgment for invalidity of ‘775 patent and ‘927 patent under § 101 is denied.

Abstract Idea:

Yes for ‘775 patent; no for ‘927 patent.

Something More:

Yes for both patents.

Technology:              

Method for communicating two different types of data at different rates over a common communication link. (‘775 patent); varying length of time alert stays on based on vehicle speed (‘927 patent).

Summary:                 

The court found the ‘775 patent to be valid under § 101 because the specific claim limitations recited a “specific process for transforming two types of data into a single data stream.” Thus, even if the underlying process was potentially an abstract idea, the specific mechanism to solve the issue offered something more. As to the ‘927 patent, the court found that the patent was directed at something that was not an abstract idea and even if it was an abstract idea, it was “something more.” In particular, it offers a technical solution to the technical problem of “sustaining the blind-spot alert for some period of time, based on the relative speed of the host and target vehicle.”