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Alice is clear that inventions drawn to automating well-known concepts are not patent-eligible. However, this area of the law becomes a bit murky when the automated concept is one that involves concrete or physical devices. The District of Minnesota recently issued an opinion bearing on the patentability of automatic price quotations for injection molds.
In the case of Proto Labs, Inc. v. ICO Products, LLC, Civil No. 15-2562 (D. Minn. July 28, 2016 Report and Recommendation on Motion to Dismiss), the court found patents directed to automatically generating a price quotation for a mold were directed to abstract ideas with no further inventive concept. The patents at issue generally related to "providing automated price quotations for molds and molded parts and contemplates the use of a computer or the internet to perform a variety of functions throughout the quotation process." Specifically, the patents involve sending a CAD file of the mold or parts, analyzing the CAD file to determine geometric intricacies that may increase the cost for preparing the mold, and then having the customer select various parameters (number of mold cavities, surface finish and material, delivery time, etc.) that all factor in to the overall cost of the mold manufacturing process. The parameters are then run through an algorithm to provide an estimate for producing the mold.
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