In CONTENT EXTRACTION & TRANSMISSION, LLC, v. WELLS FARGO BANK, NATIONAL ASSOCIATION, Appeal Nos. 2013-1588, 2013-1589, 2014-1112, and 2014-1687, the Federal Circuit affirmed the district court’s grant of the defendant’s motion to dismiss under FRCP 12(b)(6) because the asserted data collection claims were invalid as directed to an unpatentable abstract idea.
CET asserted four patents claiming methods for collecting, recognizing, and storing data from a hard copy document, such as a check collected at an ATM. The representative independent claims included collecting data “using an automated digitizing unit such as a scanner.” The district court found all of the asserted patents invalid under 35 U.S.C. § 101 and granted a motion to dismiss under FRCP 12(b)(6) based on this ineligibility ground.
The Federal Circuit affirmed the grant of the motion to dismiss. The Federal Circuit applied the two-step framework of Mayo Collaborative Services v. Prometheus Laboratories, Inc., 132 S. Ct. 1289 (2012) and Alice Corp. v. CLS Bank International, 134 S. Ct. 2347 (2014) to the representative independent claims. Under step one, addressing whether the claims were directed to an abstract idea, the Federal Circuit agreed the abstract idea of “data collection, recognition, and storage is undisputedly well-known.” Under step two, addressing whether the claims were a patent-eligible application of an abstract idea, the Federal Circuit determined “the use of a scanner or other digitizing device to extract data from a document” was a well-known application: the claims merely recited the use of “existing scanning and processing technology to recognize and store data.”
CET argued the dependent claims recited additional steps rendering those claims patent eligible. The Federal Circuit disagreed and concluded those claims recited “well-known, routine, and conventional functions of scanners and computers.” Thus, “while these claims may have a narrower scope than the representative claims, no claim contains an ‘inventive concept’ that transforms the corresponding claim into a patent-eligible application of an otherwise ineligible abstract idea.”
Finally, the Federal Circuit concluded the district court properly resolved the motion to dismiss at the pleading stage because, even when construed in a manner most favorable to CET, none of the claims amounted to “‘significantly more’ than the abstract idea of extracting and storing data from hard copy documents using generic scanning and processing technology.”