Synopsys, Inc. v. Siemens Industry Software Inc.
- William Orrick
- 3:20-cv-04151
- U.S. District Court · Northern District of California
- 18
In Synopsys v. Avatar, Judge Orrick granted dismissal of Claims I and II but denied dismissal of Claim VI in a patent-eligibility dispute.
Synopsys, Inc.’s patent-infringement claims involving the ’863 and ’640 patents were dismissed through Claims I and II; the Claim VI dispute involving the ’655 patent was allowed to continue against Avatar Integrated Systems, Inc.
What happened
Synopsys, Inc. v. Avatar Integrated Systems, Inc. involved Avatar’s request to dismiss three patent-infringement claims. Avatar argued that the patents covered abstract mental processes or mathematical calculations and therefore did not claim patent-eligible inventions.
Judge Orrick ruled that the ’863 patent’s method for keeping only relevant circuit-design information and the ’640 patent’s statistical timing calculations were abstract and lacked an inventive concept. He ruled that the ’655 patent described a specific computer-based method for checking design changes across multiple chip-design scenarios without repeatedly swapping large data files in and out of memory.
Judge Orrick granted Avatar’s motion to dismiss as to Claims I and II and denied the motion as to Claim VI. The opinion therefore left the claim involving the ’655 patent in the case while dismissing the claims involving the ’863 and ’640 patents.
The detailed version
- Synopsys, Inc. v. Siemens Industry Software Inc. · No. 3:20-cv-04151
- William Orrick
- Nov. 12, 2020
Background
Synopsys, Inc. sued Avatar Integrated Systems, Inc. for patent infringement. Avatar moved under Federal Rule of Civil Procedure 12(b)(6), which allows dismissal when a complaint does not state a legally sufficient claim. Avatar challenged three of the six asserted patent-infringement claims under 35 U.S.C. § 101, the Patent Act’s provision identifying patentable subject matter.
The court applied the two-step test from Alice Corp. v. CLS Bank. First, it asked whether the patent claims were directed to an abstract idea, such as a mental process or mathematical method. If so, it asked whether the claims contained an “inventive concept”—an element or combination that added significantly more than the abstract idea itself.
The ’863 Patent
The ’863 patent concerns representing part of a hierarchical integrated-circuit design. Its representative claim describes retaining selected physical-interconnect information and selected cells from a circuit block, then using that reduced representation in another development phase.
The court held that the claim was directed to the abstract idea of discarding irrelevant information and retaining a desired subset. Limiting that process to integrated-circuit design did not make it non-abstract. The court also rejected Synopsys’s argument that the claim used an inventive data structure or improved computer functionality. In the court’s view, the claimed advance concerned the type and quality of data used, not an improvement to how the computer itself functioned.
At the second Alice step, the court found no inventive concept. The claim did not require a specific structure or an unconventional arrangement of computer components; identifying a generic computer-readable medium was insufficient. The court concluded that the ’863 patent was invalid under § 101.
The ’640 Patent
The ’640 patent concerns statistical static timing analysis of integrated circuits. Its representative claim uses nominal-delay and standard-deviation values, mathematical operations, and a statistical maximum to calculate timing information for converging circuit paths.
The court held that the patent was directed to the abstract idea of a mathematical algorithm or method of calculation. Although the method was specific and tied to circuit timing analysis, the court concluded that a narrow method of performing statistical analysis remained abstract. The court also found no inventive concept because the claimed sequence of mathematical operations was the abstract statistical-analysis method itself, rather than something significantly more.
The court therefore concluded that the ’640 patent was invalid under § 101.
The ’655 Patent
The ’655 patent concerns fixing circuit-design requirement violations across multiple process, operating-condition, and operating-mode combinations. The patent uses a scenario image and a smaller multi-scenario engineering-change-order database to estimate how a proposed design change will affect other scenarios.
The court held that the claims were directed to a specific method for checking engineering-change orders across multiple scenarios while avoiding repeated swapping of large scenario images between computer storage and memory. Accepting the allegations in Synopsys’s favor at the dismissal stage, the court found that this method improved the efficient use of computers and was not an abstract concept.
The court further stated that, even if the ’655 patent were directed to an abstract idea, its unconventional use of the engineering-change-order database and scenario image would supply an inventive concept. The court concluded that the ’655 patent was not invalid under § 101.
Disposition
Judge William Orrick granted Avatar’s motion to dismiss as to Claims I and II and denied the motion as to Claim VI. The opinion states that the ’863 and ’640 patents were invalid under § 101 and that the ’655 patent was not invalid under § 101. Under the requested classification convention, this is a procedural order because the ruling was made on a Rule 12(b)(6) motion to dismiss, even though the court addressed patent eligibility.
Read the full 18-page opinion on CourtListener, the free public archive maintained by the Free Law Project.