Dental Monitoring SAS v. Align Technology, Inc.

Dental Monitoring SAS v. Align Technology, Inc. The Federal Circuit affirmed summary judgment that the asserted claims are patent-ineligible under § 101. The claims were directed to abstract ideas of acquiring, analyzing, and reporting image information, and reciting a generic deep learning device trained on dental images did not supply an inventive concept. The decision reinforces that applying generic machine-learning tools to a new medical or dental imaging context, including with domain-specific training data, may not be enough for eligibility under Alice. Affirmed. The claims covered using a cellphone or acquisition device to capture dental-arch or aligner images, analyze them with a trained deep learning device, and provide results or guidance. At Alice step one, the court treated the claims as part of the Electric Power Group line: collecting information, analyzing it, and displaying or sending results. The claimed “deep learning device” did not change the eligibility analysis because the specifications described conventional neural-network options, and the claimed training on more than 1,000 dental images was considered inherent to machine learning rather than a technological improvement. At Alice step two, the court found no inventive concept; using generic machine-learning components to perform orthodontic assessment more efficiently did not make the claims significantly more than the abstract idea. The court affirmed invalidity of claims 1 and 14 of the '248 patent and claims 1, 7, and 12 of the '409 patent under § 101. § 101 infringement non-precedential § 101 infringement non-precedential § 101 non-precedential