Judge Failla Not “On Board” with Amtrak’s Section 101 Arguments in Train-Traffic-Control Case

Patterson Belknap Webb & Tyler LLP

Patterson Belknap Webb & Tyler LLP

In a patent case involving claims directed to train-traffic-control systems, Judge Failla of the Southern District of New York denied Defendant Amtrak’s motion to dismiss, rejecting Amtrak’s arguments that Plaintiff Railware, Inc.’s patent claims were directed to an abstract idea. See Railware, Inc. v. Nat’l R.R. Passenger Corp., No. 22 Civ. 5013 (KPF), 2023 WL 5432860, at *1 (S.D.N.Y. Aug. 23, 2023).

Train-traffic-control systems divert trains away from sections of railroad tracks by blocking sections of the tracks where, for example, railway workers are active. Id. In some systems, one dispatcher is solely responsible for unblocking the track sections when it is safe to do so. Id. Railware’s patent claims, however, require participation from both dispatchers and employees in the field to unblock track sections. Id. Specifically, each time a track section is blocked, the claimed system generates a code and sends it to an employee in the field. Id. The section can be unblocked only when the employee in the field sends the code back to the dispatcher. Id.

In 2022, Railware sued Amtrak, alleging that Amtrak’s train-traffic-control system infringed Railware’s patents. Id. at *3. Amtrak moved to dismiss the case, arguing that the asserted claims were ineligible for patent protection under 35 U.S.C. § 101. Id. at *6.

To distinguish between eligible and ineligible patent claims, courts apply a two-step test called the Alice/Mayo test. At the first step, courts consider “whether the [patent] claim is directed to a patent-ineligible concept such as a law of nature, a natural phenomenon, or an abstract idea.” Id. at *5. If the claim is directed to a patent-ineligible concept, courts proceed to the second step and “consider the elements of each claim both individually and as an ordered combination to determine whether the additional elements transform the nature of the claim into a patent-eligible application” that includes an “inventive concept.” Id. (quoting CardioNet, LLC v. InfoBionic Inc., 955 F.3d 1358, 1368 (Fed. Cir. 2020)). “For a claim to include an ‘inventive concept,’ it must ‘involve more than performance of well-understood, routine, and conventional activities previously known to the industry.’” Id. (quoting Berkheimer v. HP Inc., 881 F.3d 1360, 1367 (Fed. Cir. 2018)).

At the first step of the Alice/Mayo test, the court concluded that the asserted claims “provide for an innovative method of achieving a specific result.” Id. at *8. Specifically, the court reasoned that “[t]he asserted claims do not merely introduce a network component to railroad control, nor do they simply describe a process for achieving an abstract end”; rather, they “modify traditional centralized railroad control systems by dividing control of the blocking and unblocking process between a central dispatcher and workers in the field . . . to solve the specific problem of central dispatchers erroneously removing blocks prematurely.” Id. Thus, the court held, the patent claims were “potentially patent-eligible.” Id. at *10.

Though not required to reach the second step of the Alice/Mayo test, the court noted that it would reach the same conclusion if it did proceed to the second step. Id. Judge Failla was “inclined to agree” that Railware’s patents do more than introduce “generic computer network components to achieve an abstract end.” Id. at *11.

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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