Digest of INTERNET PATENTS CORPORATION V. ACTIVE NETWORK, INC., Nos. 2014-1048, 2014-1061, 2014-1062, 2014-1063 (Fed. Cir. June 23, 2015) (precedential). On appeal from the N.D. Cal. Before Newman, Moore, and Reyna.
Procedural Posture: Plaintiff patentee appealed from a judgment dismissing complaints in four related actions for infringement of a patent determined to be invalid under 35 U.S.C. §101. CAFC affirmed the district court.
- Patent Eligibility (Section 101): Claims directed to “the use of a conventional web browser Back and Forward navigational functionalities without data loss in an online application consisting of dynamically generated web pages” were ineligible subject matter under 35 U.S.C. §101. The Federal Circuit applied the two-step Bilski, Mayo,and Alice framework of determining whether the character of the claims is directed toward excluded subject matter; and if it is, determining whether there is an “inventive concept” that overcomes the abstraction. The district court did not err in finding that the claimed invention was ineligible subject matter, because retaining information in the navigation of online forms is directed toward the abstract idea of avoiding data loss, and it is “well-understood, routine, and conventional” activity that is insufficient to satisfy an “inventive concept.”