InMusic Brands, Inc. v. Sony Corporation of America

Background

InMusic Brands, Inc. alleged that Sony Corporation of America directly infringed U.S. Patent No. 7,567,498 by making, using, selling, offering for sale, or importing two accused turntables: the PS-HX500 and PS-LX310BT. The patent claims a turntable with a platter, tonearm, analog-to-digital converter, and controller. The converter and controller are built into the turntable and produce digital audio using a standard computer protocol, such as USB or FireWire.

Sony moved to dismiss under 35 U.S.C. § 101, arguing that the patent claims covered ineligible subject matter. The court considered patent eligibility on a motion to dismiss because it found no factual allegations that prevented resolving the issue as a matter of law.

Court’s Analysis

The court applied the two-step test for patent eligibility. First, it asked whether the claims were directed to an abstract idea. The court concluded that they were. In its view, the claims merely listed conventional turntable components performing their ordinary functions, including converting analog audio into digital audio and outputting that audio through a standard protocol. The court noted that analog-to-digital conversion in turntables, including built-in conversion using another digital-output system, already existed before the patent application.

Second, the court asked whether the claims contained an “inventive concept”—an element or combination that added significantly more than the abstract idea itself. The court rejected inMusic’s argument that the combination of ordinary turntable parts with a built-in converter and controller supplied that inventive concept. It concluded that the claimed use of standard protocols such as USB or FireWire was described at a high level and relied on well-understood, routine, and conventional components.

Disposition

The court held that the patent was invalid because it was directed to an abstract idea and lacked an inventive concept. Judge Hellerstein granted Sony’s motion to dismiss and directed the Clerk to enter judgment dismissing the case. The opinion does not state that the dismissal was with or without prejudice.

Classification Note

This is classified as a procedural order under the stated convention because the court disposed of the case through a motion to dismiss, even though it analyzed patent eligibility under Section 101.