Dental Laser Technology Not Abstract Idea
In a recent ruling, the Central District of California determined that certain laser implemented methods patented by Lensar, Inc. was eligible subject matter under Section 101. See June 10, 2016 Order, 15-cv-01689. Section 101 eligibility has been the subject of much debate and controversy over the past 10 years, and has been used to scuttle patents and applications directed to mostly computer implemented methods. Here, the intervenor alleged the claimed laser implemented technology was patent ineligible. The district court rejected that argument under two separate and "distinct" 101 analyses under Alice and Nuijten, with Nuijten (500 F.3d 1346 (Fed. Cir. 2007)) perhaps being the lesser known standard.
The district court explained its view that Nuijten found that a transitory "signal per se is not within one of the four categories of statutory subject matter ..." under Section 101 and analyzed the claims at hand under both that standard and the oft-discussed, but yet-to-be fully understood standard set forth in the Supreme Court's Alice ruling.
Interesting read for innovators in laser and signal technology, as well as IP legal scholars. Case can be found here.