Capstan AG Systems, Inc. v. Raven Industries, Inc. et al 5-16-cv-04132 (D. Kan. Jan. 11, 2017)
- 8,191,795 | Entitled “Method and system to control flow from individual nozzles while controlling overall system flow and pressure”
- 8,523,085 | Entitled “Method and system to control flow from individual nozzles while controlling overall system flow and pressure”
Denial of Defendant’s Motion to Dismiss
Nozzles controlled by use of pulse-width-modulation
Defendants erred in requesting the court consider whether the patents were an advancement over the prior art, improperly importing a 102/103 analysis. The court focused its analysis on the problem the claims set out to solve. That problem is patent-eligible: lack of precision in agrochemical spraying caused by the inability to control sprayer nozzles individually. Although this is completed in part by a mathematical formula, the focus of the claims was control of the nozzle, not the formula itself. Although the court noted that this alone resolved the issue, the court went on to analyze the inventive step. Construing the complaint in plaintiffs’ favor, the court credited plaintiffs’ position that the individual valve controls were not in the prior art. And the court said that given the parties’ disagreement on how to construe the claims, this dispute precluded early dismissal.