Background
Arendi S.A.R.L. sued Google LLC and Oath Holdings Inc. alleging infringement of four patents concerning identifying information in documents and searching external sources. The district court granted judgment on the pleadings for three patents, finding them ineligible under Section one hundred and one. For the fourth patent, a jury found noninfringement and invalidity, and the district court entered judgment in favor of the defendants. Arendi appealed the final judgments.
The court’s reasoning
The court analyzed the claims under the Alice two-step framework. It determined that the claims of all four patents are directed to the abstract idea of collecting information, analyzing it, and using the results to perform an action. The court found that the claims recite generic computer functions and do not improve computer functionality or provide an inventive concept sufficient to transform the abstract idea into a patent-eligible application.
We have long held that claims directed to collecting information, analyzing it, and displaying certain results of the collection and analysis are abstract.
Elec. Power Grp., LLC v. Alstom S.A., 830 F.3d 1350, 1353–54 (Fed. Cir. 2016)
What it means going forward
The decision reinforces that software patents claiming basic data processing and search functions on generic computers are likely ineligible for patent protection.