AMERICAN AXLE & MANUFACTURING, INC., v. NEAPCO HOLDINGS LLC

AMERICAN AXLE & MANUFACTURING, INC., v. NEAPCO HOLDINGS LLC, Appeal No. 2018-1763 (Fed. Cir. October 3, 2019).  Before Dyk, Moore and Taranto.  Appealed from D. Del. (Judge Stark). (Subject Matter Eligibility)

Background:

American Axle & Manufacturing (AAM) owns a patent that is directed to a method for manufacturing driveline propeller shafts with liners that are configured to attenuate vibrations through a shaft assembly.  In particular, claim 1 recites a method comprising:

(i) providing a hollow shaft member;

(ii) tuning at least one liner to attenuate at least two types of vibration transmitted through the shaft member; and

(iii) positioning the at least one liner within the shaft member such that the at least one liner is configured to damp shell mode vibrations in the shaft member by an amount that is greater than or equal to about 2%, and the at least one liner is also configured to damp bending mode vibrations in the shaft member, the at least one liner being tuned to within about ± 20% of a bending mode natural frequency of the shaft assembly as installed in the driveline system.

AAM filed an infringement suit against Neapco, and in turn Neapco filed a motion for summary judgment arguing that AAM’s claims are invalid under 35 U.S.C. §101. The district court granted the motion reasoning that AAM’s claims amounted to merely instructing one to apply the abstract idea of Hooke’s law to achieve the desired result of attenuating certain vibration modes and frequencies without reciting how to craft the liner and propeller shaft.  AAM appealed.

Issue/Holding:

Did the district court err in granting the motion to dismiss and holding that the claims of AAM’s patent were ineligible under §101?  (continue reading)

Summary by:  Patrick Gildea

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