The Federal Circuit affirmed the district court’s holding that two of the asserted patents were invalid under §101 as claiming patent ineligible subject matter and affirmed the court’s construction for “machine readable instruction form” which rendered those claims not infringed.
The first patent held invalid for patent ineligible subject matter was directed to the abstract idea of tracking financial transactions to determine whether they exceed a pre-set spending limit (i.e., budgeting). This abstract idea was no different than all of the other similar ideas that were held to be invalid, such as that in Bilski. The court further held that the claims contain no inventive concept – all of the elements are mere generic computer elements and “[i]nstructing one to ‘apply’ an abstract idea and reciting no more than generic computer components performing generic computer tasks does not make an abstract idea patentable.”
The second patent held invalid for patent ineligible subject matter was directed to the abstract idea of tailoring the content of a web page based on the viewer’s location or address or navigation data. The court held that the claims lacked an inventive concept that would support patent eligibility. The patent owner pointed to the claim element of the “interactive interface” as the inventive concept, but the court held that this element was just a generic computer element that was not an invention. Lastly, the court distinguished the DDR Holdings case from the present case on the grounds that the patent in DDR Holdings addressed problems unique to the Internet, but the claims here did not.
The court lastly held that the construction of the term “machine readable instruction form” which required a hard-copy form, rather than an electronic one, was correct because it was consistent with the claim language, the specification, and the prosecution history.
Intellectual Ventures I LLC v. Capital One Bank (USA) National Association, Case No. 2014-1506 (July 6, 2015); Opinion by: Dyk, joined by Reyna and Chen; Appealed From: District Court for the Eastern District of Virginia, Trenga, J. Read the full opinion here.