The Federal Circuit affirmed the district court’s holding, on a motion to dismiss, that the claims of the patent-at-issue were not patent eligible under Section 101. Claim 1 related to a method of using an internet browser having back and forward navigation functionalities to maintain the state when filling in a form. Applying the two-part Alice Corp. test, the court agreed that the claim was directed to the abstract idea of “retaining information in the navigation of online forms” and that claim 1 contained no restriction on how the result is accomplished. The court then discussed independent claims 9 and 17, which were identical to claim 1, but claim 9 claimed a computer system and claim 17 claimed a computer-readable storage medium. The court held that the statement that the method is performed by a computer does not satisfy the test of “inventive concept.” ‘ Other dependent claims recited further limitations, but the court held that these limitations do not add an inventive concept, because they “represent merely generic data collection steps or siting the ineligible concept in a particular environment.”
Internet Patents Corporation v. Active Network, Inc., Case Nos. 2014-1048, -1061, -1062, -1063 (June 23, 2015); Opinion by: Newman, joined by Moore and Reyna; Appealed From: District Court for the Northern District of California, White, J. Read the full opinion here.