The district court granted the defendants’ motion to dismiss under Rule 12(b)(6) on the ground that each claim of the asserted patents was invalid as patent-ineligible under § 101. The claims were characterized as a method for extracting data from a hard copy document using a scanner, recognizing information from the extracted data, and storing that information in memory. The court held that the claims are drawn to the abstract idea of collecting data, recognizing certain data, and storing the recognized data and further held that all of these concepts were well-known and were performed by humans. The fact that the claims required a structure, a scanner, in addition to a computer did not change the outcome, because, in Alice, the claims also required a computer to process streams of bits, and those claims were held to be ineligible. The court further held that the claims contained no limitations that transformed into patent-eligible subject matter. The use of a scanner and computer to interpret the scanned information was well-known at the time of the patent. Lastly, the court held that the issue of patent-eligibility does not require claim construction so long as the court has “a full understanding of the basic character of the claimed subject matter.”
Content Extraction and Transmission LLC v. Wells Fargo Bank, N.A., Case No. 2013-1588, -1589; 2014-1112, -1687 (December 23, 2014); Opinion by: Chen, joined by Dyk and Taranto; Appealed From: District of New Jersey, Shipp, J. To read the full opinion, click here.
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