Integrated Technology Solutions (“ITS”) filed suit in 2021, accusing iRacing of infringing U.S. Patent No. 10,046,241. The patent relates to in-game modifications for racetrack video games whereby the environmental conditions and actions taken by the players bring about changes in the performance of the game system during play. For example, it identifies different temperatures of different portions of the (virtual) track surface and uses that data to modify the car’s response to player inputs in a way that would mimic the real-life performance of a race car on tracks of the different temperatures. ITS asserted that iRacing’s racing software infringed the claims directly, and that its subscription service induced and contributed to infringement.
Judge Talwani granted iRacing’s motion to dismiss, finding the claims were directed to patent-ineligible concepts. She agreed with iRacing that the basic thrust of the claims was the abstract idea of simulating the impact of a racetrack surface on a vehicle’s performance, with the claims laying out a series of generic steps that describe this raw concept without actually claiming a specific way in which the simulation is made. She noted that the patent does not specify how to perform the claimed concepts and is overly broad in specifying variations identified. Relying on a Federal Circuit holding that “claims directed to generalized steps to be performed on a computer using conventional computer activity are not patent eligible,” Judge Talwani determined that the claims do not place limitations on how the claimed components identify, check, determine and modify the racing area, and that the specification does not spell out how the elements actually achieve the intended goals, but merely restate the goals. That the patent sought to limit the claims to racetrack simulations, eligibility cannot be found by limiting an abstract idea to a particular technological environment. Judge Talwani rejected ITS’ assertion that the patent offered an improvement to computer technology – map rendering – because the patent failed to specify the technological means for improvements of map rendering. Accordingly, the ‘241 patent was deemed invalid and the complaint was dismissed.
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