Am. Axle & Mfg. v. Neapco Holdings LLC
United States Court of Appeals for the Federal Circuit
October 3, 2019, Decided
[*1357] Dyk, Circuit Judge.
American Axle & Manufacturing, Inc. ("AAM") sued Neapco Holdings LLC and Neapco Drivelines LLC (collectively, "Neapco") alleging infringement of claims of U.S. Patent No. 7,774,911 ("the '911 patent"). The parties filed cross-motions for [*1358] summary [**2] judgment as to the eligibility of the asserted claims of the '911 patent under 35 U.S.C. § 101. The district court granted Neapco's motion and held that the asserted claims are ineligible under § 101. We agree and therefore affirm.
The '911 patent generally relates to a method for manufacturing driveline propeller shafts ("propshafts") with liners that are designed to "attenuat[e] . . . vibrations transmitted through a shaft assembly." '911 patent, col. 1, ll. 6-7. Propshafts are "employed [in automotive vehicles] to transmit rotary power in a driveline." Id. col. 1, ll. 38-39. Because these propshafts are typically made of a "relatively thin-walled steel or aluminum tubing [they] can be receptive to various driveline excitation sources." Id. col. 1, ll. 40-42. These excitation sources, in turn, can cause the propshaft to vibrate in three modes: bending mode, torsion mode, and shell mode. Id. col. 1, ll. 42-44. The '911 patent describes these vibration modes as follows:
Bending mode vibration is a phenomenon wherein energy is transmitted longitudinally along the shaft and causes the shaft to bend at one or more locations. Torsion mode vibration is a phenomenon wherein energy is transmitted [**3] tangentially through the shaft and causes the shaft to twist. Shell mode vibration is a phenomenon wherein a standing wave is transmitted circumferentially about the shaft and causes the cross-section of the shaft to deflect or bend along one or more axes.
Id. col. 1, ll. 44-52. These vibration modes correspond to different frequencies. Because such vibrations cause undesirable noise, "techniques [had, prior to the '911 patent,] been employed to attenuate vibrations in propshafts including the use of weights and liners." Id. col. 1, ll. 53-54.Read The Full CaseNot a Lexis Advance subscriber? Try it out for free.
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939 F.3d 1355 *; 2019 U.S. App. LEXIS 29655 **; 2019 U.S.P.Q.2D (BNA) 377579; 2019 WL 4865832
AMERICAN AXLE & MANUFACTURING, INC., Plaintiff-Appellant v. NEAPCO HOLDINGS LLC, NEAPCO DRIVELINES LLC, Defendants-Appellees
Prior History: [**1] Appeal from the United States District Court for the District of Delaware in No. 1:15-cv-01168-LPS, Chief Judge Leonard P. Stark.
Am. Axle & Mfg. v. Neapco Holdings LLC, 2016 U.S. Dist. LEXIS 198332 (D. Del., Sept. 23, 2016)
liner, vibration, patent, bending, tuning, attenuation, inventive, frequencies, shaft, propshaft, damping, driveline, eligible, natural law, shell, ineligible, patentee, variables, prior art, dampen, steps, specification, district court, stiffness, modes, laws of nature, manufacturing, conventional, positioning, experimental
Civil Procedure, Judgments, Summary Judgment, Entitlement as Matter of Law, Appeals, Summary Judgment Review, Standards of Review, Patent Law, Jurisdiction & Review, Standards of Review, De Novo Review, Subject Matter, Specifications, Enablement Requirement, Scope of Enablement