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."
