• CRS Advanced Technologies, Inc. v. Frontline Technologies, Inc.All claims unpatentable
  PTAB · Jan 21, 2014 · CBM2012-00005 · APJ Jennifer S Bisk · CBM · Final written decision

  Claims 3, 6, 7, 16, 24, and 33 are unpatentable under § 101 because they claim abstract substitute fulfillment using generic computing technology without meaningful limitations.

  RulingsFinal written decision

  • Claim Construction › Threshold & procedure › Whether a term needs construction (O2 Micro)No construction neededNot reached

    “the act of conveying or supplying for use making information available For each of the claim terms discussed above, we conclude that either definition would result in the same § 101 analysis. In other words, each of the challenged claims is unpatentable under § 101 whether or not we adopt CRS’s proposed claim constructions. Therefore, we conclude that each of the claim terms is given its ordinary and customary meaning and the issue of claim construction will not be addressed further.” slip op. at 8

  • Patent Eligibility (§101) › Alice/Mayo step one — 'directed to'Step1 directed to exceptionUnpatentable

    “We conclude that claims 3, 16, 24, and 33 are directed to abstract, and, therefore, unpatentable, methods for substitute fulfillment. The claims are directed to concepts for taking the preexisting process of substitute fulfillment and implementing it in a networked computing environment. We do not agree with Frontline’s argument that the computer technology is integral to the claimed subject matter. As we explained in the Decision to Institute, the “one or more computers,” “Internet communication link,” and “website” recited in claim 3 are not analogous to the GPS receiver in SiRF. Decision to Institute 10-11. Frontline has not directed us to anything in the record at trial to cause us to change our position. Frontline asserts that because the claimed limitations “generating and posting by one or more computers a list of one or more positions of one or more absent workers that need to be filed by one or more substitute workers on a website” and “receiving via at least one communication link absentee information” are required for the claimed process to work as intended, they, like the GPS receiver in SiRF, are integral to the claimed subject matter. PO Resp. 25-26. We, however, disagree. We find these additions of generic computer technology to be more akin to the addition of “computer-aided” to the claims of Dealertrack, and the additions of “transaction database” and “transmitting information” to the claims of Accenture. Accenture, 728 F.3d at 1339; Dealertrack, 674 F. 3d at 1333. Like the terms “computer-aided” in Dealertrack, and “transaction database” in Accenture, the terms “one or more computers,” “website,” and “communication link” at issue in this case do not impose meaningful limits on the challenged claims’ scope. This particular technology is employed only for the purposes of creating more efficient communication and data storage—basic functions of those components. Ex. 1001, col. 4, ll. 46-58 (stating that the advantages of the present invention are “to provide a reliable, efficient system . . . . that has low overhead and requires little . . . oversight. . . . includ[ing] an interface to the Internet . . . .[and] a central database”); see also col. 3, ll. 36-64 (describing the prior art automated systems). In other words, the claims here, even with the recitation of computing technology, are not part of a “technological advance” of any sort. See Bancorp, 687 F.3d at 1279.” slip op. at 13

  • Patent Eligibility (§101) › Alice/Mayo step two — inventive conceptStep2 no inventive conceptUnpatentable

    “Like the terms “computer-aided” in Dealertrack, and “transaction database” in Accenture, the terms “one or more computers,” “website,” and “communication link” at issue in this case do not impose meaningful limits on the challenged claims’ scope. This particular technology is employed only for the purposes of creating more efficient communication and data storage—basic functions of those components. Ex. 1001, col. 4, ll. 46-58 (stating that the advantages of the present invention are “to provide a reliable, efficient system . . . . that has low overhead and requires little . . . oversight. . . . includ[ing] an interface to the Internet . . . .[and] a central database”); see also col. 3, ll. 36-64 (describing the prior art automated systems). In other words, the claims here, even with the recitation of computing technology, are not part of a “technological advance” of any sort. See Bancorp, 687 F.3d at 1279.” slip op. at 14

  Patent outcomesUS 6,675,151 unpatentable
  Claim construction§ 101 eligibility
  Patents in suitUS 6,675,151

Holdings, summaries, rulings, issues, outcomes, winners and claim constructions shown for a decision were generated by a large language model reading the opinion. They are a guide to the decision, not the decision. Confirm every one against the court's own text before relying on it. Outcomes read from the patent owner’s side. Party names are extracted from the decision and are missing on about 900 short Director denials and scans, which carry the trial number instead.