Amsted Rail Company v. Squires
Panel: Prost, Chen, Stark
The Federal Circuit affirmed the Patent Trial and Appeal Board's determination that claims 1, 21–30, 36, and 37 of Amsted Rail Company's U.S. Patent No. 10,137,915—directed to systems for detecting operational anomalies on trains—were unpatentable under § 103, and affirmed the Board's denial of Amsted's motion to amend with substitute claims 38–48. Amsted challenged the Board's claim construction, substantial evidence supporting motivation to combine prior art references Armitage and Barone, and the denial of its motion to substitute claims adding tri-axis sensor, plurality-of-filters, and plurality-of-detectors limitations.
The court applied dependent claim differentiation to reject Amsted's proposed temporal ordering between sensing and filtering functions in claim 1, finding that dependent claim 23—which recites filters "disposed to remove the undesirable accelerations before the undesirable accelerations reach the one or more sensors"—forecloses a construction requiring filtering to occur after sensing. The court credited the Board's reliance on expert testimony that a skilled artisan would understand how to implement Barone's general data-filtering principles digitally on Armitage's firmware, notwithstanding that Barone itself disclosed analog filtering. On the motion to amend, the court found substantial evidence supporting the Board's conclusion that Armitage's disclosure of a 3-D accelerometer monitoring "a single axis" in "some examples" reasonably teaches capability to monitor multiple axes in other instances.