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Patent Subject Matter Eligibility

Federal Circuit
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Digitech Image Technologies v. Electronics for Imaging — Federal Circuit Holds Data Structures and Mathematical Relationships Are Not Patentable

The Federal Circuit held that a patent claiming an image device profile — a collection of color and spatial data — was patent-ineligible, finding that a data structure without physical embodiment is not patentable, and that methods consisting only of mathematical correlations are abstract ideas.

Federal Circuit
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Ultramercial v. Hulu — Federal Circuit’s Evolving § 101 Analysis for Internet Advertising Patents

The Federal Circuit initially held Ultramercial’s patent on a method of distributing copyrighted media over the internet by requiring viewers to watch an advertisement to be patent-eligible — but after Supreme Court remand in light of Alice v. CLS Bank, reversed and found the claims directed t

Federal Circuit
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CLS Bank International v. Alice Corp. — Federal Circuit En Banc Produces Fractured § 101 Ruling on Software Patents

Ten Federal Circuit judges issued seven different opinions and could not agree on a single legal standard for software patent eligibility under § 101, affirming by an evenly divided court that Alice’s financial settlement patents were invalid — a fractured ruling that led directly to the Supre

Federal Circuit
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Alice Corp. v. CLS Bank (Federal Circuit En Banc 2013) — Court Fragments Over § 101 Framework for Software Patents

The Federal Circuit, sitting en banc, affirmed invalidity of Alice’s financial settlement software patent claims — but produced seven separate opinions with no majority rationale, reflecting deep disagreement on how to apply § 101 to software and setting the stage for the Supreme Court’s

Federal Circuit
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Bancorp Services v. Sun Life Assurance — Federal Circuit Holds Life Insurance Valuation Patents Invalid as Abstract Ideas

The Federal Circuit held that patents on computer-implemented methods for managing stable-value life insurance policies are directed to an abstract idea and therefore invalid under § 101, ruling that adding generic computer implementation to an abstract mathematical algorithm does not create patent-

Federal Circuit
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Orthokinetics v. Safety Travel Chairs — Federal Circuit on Product-by-Process Claims and Definiteness

The Federal Circuit held that MySpace’s social networking website did not infringe Graphon’s patents on searchable online databases, finding the asserted claims invalid as obvious combinations of well-known internet database and search technologies — an important post-KSR ruling on obvio

Federal Circuit
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Dealertrack v. Huber — Federal Circuit Holds Computer-Aided Credit Application Clearinghouse Is Patent-Ineligible Abstract Idea

The Federal Circuit held that Dealertrack’s claims covering a computer-aided system for routing automobile dealer credit applications to lenders were directed to the unpatentable abstract idea of processing credit applications — striking down the patents under § 101 because adding ‘apply

Federal Circuit
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Ultramercial v. Hulu — Federal Circuit Holds Internet Advertising-as-Currency Patent Eligible Under § 101

The Federal Circuit reversed a district court dismissal and held that Ultramercial’s patent on distributing copyrighted content free-to-consumers in exchange for viewing advertisements was patent-eligible subject matter under § 101 — finding the multi-step process involved meaningful, non-abst

Federal Circuit
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Classen Immunotherapies v. Biogen IDEC — Federal Circuit Addresses § 101 for Vaccination Scheduling Method Claims

The Federal Circuit held that Classen Immunotherapies’ method claims for identifying optimal vaccination schedules to reduce chronic immune-mediated disorders were patent-eligible under § 101 in part — distinguishing between claims that merely require correlating a natural relationship and cla

Federal Circuit
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CyberSource Corp. v. Retail Decisions — Federal Circuit Holds Credit Card Fraud Detection Method Is Unpatentable Mental Process

The Federal Circuit held that CyberSource’s patent on a method of detecting credit card fraud by tracking internet addresses was directed to an unpatentable mental process — a gathering and comparing of information that a human could perform in their mind — and that reciting a Beauregard compu

Federal Circuit
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Prometheus Laboratories v. Mayo Collaborative Services — Federal Circuit Upholds Diagnostic Method Patents (Later Reversed by Supreme Court)

The Federal Circuit upheld Prometheus’s patents on methods for optimizing thiopurine drug dosing based on metabolite blood levels, holding the claims directed to patent-eligible subject matter because they applied natural correlations through a physical transformation — a ruling the Supreme Co

Federal Circuit
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Research Corp. Technologies v. Microsoft — Federal Circuit Upholds Halftone Image Patents Under § 101, Rejects Overly Rigid Abstraction Test

The Federal Circuit upheld patents on digital image halftoning technology as patent-eligible subject matter, holding that mathematical algorithms applied to specific, practical technological problems are not so abstract as to be excluded from § 101, and cautioning against an overly rigid application

Federal Circuit
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Prometheus Laboratories v. Mayo Collaborative Services — Federal Circuit Upholds Metabolite Diagnostic Patents Under § 101

The Federal Circuit upheld Prometheus Laboratories’ patents on methods of optimizing thiopurine drug dosage by measuring metabolite levels in patients, finding the diagnostic methods patent-eligible under § 101 because the claimed steps transformed an article — a patient’s blood — by det

Federal Circuit
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State Street Bank & Trust v. Signature Financial Group — Federal Circuit Validates Business Method Patents

The Federal Circuit held that business method patents are not categorically excluded from patentability — upholding a patent on a computerized financial data processing system for mutual fund management and establishing the ‘useful, concrete, and tangible result’ test for software and bu

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