SIMIO, LLC V. FLEXSIM SOFTWARE PRODUCTS,
INC.
Before Prost, Clevenger, and Stoll. Appeal from the United
States District Court for the District of Utah.
Summary: A claim whose only inventive concept is the
applications of an abstract idea using conventional and
well-understood techniques is not sufficient to transform the claim
into a patent-eligible idea.
Simio sued FlexSim Software Products ("FlexSim") for
infringing its patent directed to creating object-oriented
simulations using graphics instead of coding to allow the user to
more easily build the simulations. FlexSim moved to dismiss the
complaint for failure to state a claim, arguing that Simio's
asserted claims were abstract ideas that were ineligible for
patenting under § 101. The District Court dismissed the
complaint, finding that Simio's claims were not patent eligible
under Alice's two-step framework. Simio then filed a
motion for reconsideration, which the District Court denied. Simio
appealed.
