Judge Richard G. Andrews recently denied a motion for judgment on the pleadings that the plaintiff’s volume control patents and pairing patents claimed unpatentable subject matter under 35 U.S.C. § 101. Sonos, Inc. v. D&M Holdings Inc., C.A. No. 14-1330-RGA (D. Del. Mar. 13, 2017). The defendants argued that the “Volume patents are directed to the abstract idea of ‘controlling audio settings for multiple audio devices,'” a “very basic” concept. Id. at 8. Judge Andrews disagreed, though, and explained that “the invention as claimed in each of the Volume patents represents a substantial improvement over the existing technology – the invention described in the patents allows for the audio devices to be grouped and regrouped in real time simply using a user interface to select the desired members of the groups without the need for altering any hard wiring in the physical system. This is not simply a ‘more efficient’ method of doing something already done by humans. It is a method that provides for capabilities far beyond what a traditional hardwired system offers.” Id. at 12. The Court also rejected the argument that the pairing patents were no more than an abstract idea, explaining “the Pairing patents claim methods that involve specific devices (playback devices and controllers) that are described in the specification.” Id. at 15. Further, “the claimed methods do not simply represent an automation of something done manually. . . . This simply is not the kind of method that could be performed manually, and, even if it were, automating the method as claimed represents a substantial improvement to the functionality of the specific device.” Id.