District courts continue to consider patent-eligibility under 35 U.S.C. § 101 at the pleadings stage of patent cases. The following three decisions all came on motions made under FRCP 12. Two of the motions were granted, and one was dismissed without prejudice as premature.
StoneEagle Servs. V. Pay-Plus Solutions, Inc., Case No. 8:13-cv-2240-T-33MAP (M.D. Fla. Feb. 2, 2015). Denied (without prejudice) a defense motion under FRCP 12(c) for judgment on the pleadings under 35 U.S.C. § 101. Plaintiff alleged infringement of U.S. Reissue Patent Nos. RE43,904 E, and US RE44,748 E. The patent claims encompassed “a healthcare provider reimbursement system, by which a payor, such as an insurance company, makes ‘a virtual payment to a medical provider by transmitting a stored-value card account payment of the authorized benefit amount, together with an explanation of benefits.’” The court found the question of patent-eligibility to have been prematurely raised, in part because both parties had cited documents outside of the pleadings, and the court was not ready to hear a summary judgment motion. The court also thought claim construction should be done before the motion was heard.
Vehicle Intelligence & Safety LLC v. Mercedes-Benz USA, LLC, No. 13 C 4417 (N.D. Ill. Jan. 29, 2015). Granted a defense motion under FRCP 12(c) for judgment on the pleadings declaring United States Patent No. 7,394,392 invalid as not patent-eligible under 35 U.S.C. § 101. The patent claimed “[m]ethods and systems using one or more expert systems to screen equipment operators for impairments, such as intoxication, physical impairment, medical impairment, or emotional impairment.” The court found the claims lacking an inventive concept. Additionally, the court agreed that the “components of the ‘expert system’ of the '392 patent cover hardware and software that fall squarely within the category of generic computer components that courts have held to be insufficient under § 101.”
Money Suite Co. v. 21st Century Ins. & Fin. Servs., C.A. Nos. 13-984-GMS; 13-985-GMS; 13-986-GMS; 13-1747-GMS; 13-1748-GMS (D. Del. Jan. 27, 2015). Claims of U.S. Patent No. 6,684,189 were held patent-ineligible under 35 U.S.C. § 101, and a Rule 12(b)(6) motion to dismiss was granted. The patent “describes a computerized method for generating price quotes for financial products.” Patent claims were invalid under Section 101 “as they claim the abstract concept of assigning prices to financial products and services without meaningfully narrowing the scope of coverage.” There was not sufficient evidence of an inventive concept.
Thanks to law clerk Robert Billings for his assistance in preparing this post.
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