Internet Patents Corp. v. Active Network, Inc., __ F.3d __ (Fed. Cir. June 23, 2015) (NEWMAN, Moore, Reyna) (N.D. Cal.: White) (2 of 5 stars)

Federal Circuit affirms Rule 12(b)(6) dismissal based on invalidity under section 101.  The patent was directed to a method of using of a web browser’s back and forward buttons without data loss.  The claims were invalid under the two-step Mayo/Alice framework.

Under Mayo/Alice step one, the claims were directed to the abstract idea—“the idea of retaining information in the navigation of online forms.”  Slip op. at 10.  UnderMayo/Alice step two, none of the claims included the required “inventive concept.”  The limitations related to the back and forward buttons were inadequate, because the specification itself referred to these buttons as “conventional,” “well-known,” and “common.”  Moreover, the limitation of “maintaining the state” of a filled out form was insufficient because it contained “no restriction on how the result is accomplished.”  Id.  Other claims reciting generic computers, “generic data collection steps,” or limitations “siting the ineligible concept in a particular technological environment” also did not add an inventive concept.