Natural Law And Patent: American Axle Case

American Axle involved allegations of infringement of a patent pertaining to a method for attenuating driveline vibrations in order to reduce vehicle noise. The district court applied the Supreme Court's two-step framework for analyzing patent ineligibility and held that the asserted claims were patent ineligible. The court found that the claims were "directed to" natural laws because they involved the "mere application" of Hooke's Law and friction damping, and that any remaining elements of the claims consisted of "well-understood, routine, conventional activity already engaged in by the scientific community," which "added nothing significant beyond the sum of their parts taken separately."