With counterpoint by Gregory Hopewell
In reading post-Mayo/Alice decisions, some seem more comfortable than others. I’ve been having a tough time getting my head and heart around a recent decision from Judge Leonard Stark of the District of Delaware. The case is American Axle & Manufacturing v. Neapco Holdings and Neapco Drivelines. From the party names alone, this does not appear to be a likely candidate for Section 101 invalidity.
The claims that the court found representative for Section 101 analysis confirm that we’re not talking about social media applications or financial methods here, but instead “a method for manufacturing a shaft assembly of a driveline system.” Classic auto industry innovation dispute between two Detroit area companies, with a bonus that the judge also hails from Detroit. Spoiler Alert: To my surprise, the first sentence of the opinion’s discussion section said, “As explained below, the Court has determined that the Asserted Claims are not directed to patentable subject matter.”