Federal Circuit Summary
Before Judges Reyna, Bryson, and Stoll. Appeal from the United States District Court for the District of Delaware.
Summary: A claim that recites a specific method for navigating through three-dimensional electronic spreadsheets is not directed to an abstract idea.
Data Engine Technologies LLC (“DET”) filed suit against Google LLC asserting patents that generally relate to a method for tracking changes in an electronic spreadsheet (“Track-Changes Patent”) and navigating through a spreadsheet using tabs that allow the user to “flip through” the different spreadsheet pages (“Tab Patents”). The district court entered a judgment on the pleadings, holding that the asserted claims were ineligible under 35 U.S.C. §101 for being directed to abstract ideas and failing to provide an inventive concept. DET appealed to the Federal Circuit.
Regarding the Tab Patents, the Federal Circuit held that all but one of the asserted claims are directed to patent-eligible subject matter. The Federal Circuit stated that “[w]hen considered as a whole, and in light of the specification, [the claims are] not directed to an abstract idea. Rather, the claims are directed to a specific method for navigating through three-dimensional electronic spreadsheets.” The Federal Circuit emphasized that “although these spreadsheet interfaces have become ubiquitous, Quattro Pro, the first commercial embodiment of the claimed invention, was highly acclaimed as having revolutionized three-dimensional electronic spreadsheets” and “the method provides a specific solution to then-existing technological problems in computers and prior art electronic spreadsheets.” Also important to the Federal Circuit’s analysis was the fact that the Tab Patents required a specific interface and implementation for navigating the spreadsheets using techniques unique to computers. For instance, the Tab Patents’ claims recite specific steps for navigating between spreadsheet pages and require displaying a row of spreadsheet page identifiers (i.e., tabs) and allowing user-settable labels for the tabs. Thus, the Federal Circuit held that, with the exception of one claim, the asserted claims of the Tab Patents are directed to patent-eligible subject matter.
Turning to the Track-Changes Patent, the Federal Circuit stated that “at their core, these claims recite tracking changes in a spreadsheet by: (1) creating a base version of a spreadsheet, (2) creating a new version of the spreadsheet, and (3) determining which cells of data have changed by comparing the new and base versions.” The Federal Circuit explained that unlike the Tab patents, “nothing in the [Track-Changes Patent]’s claims viewed in light of the specification convinces us that the claimed method improves spreadsheet functionality in a specific way sufficient to render the claims not abstract.” Thus, the Federal Circuit held that the asserted claims of the Track-Changes Patent are directed to the abstract idea of collecting, recognizing, and storing the recognized data in memory and that the claims do not recite an inventive concept under Alice step two. Thus, the Federal Circuit affirmed-in-part, reversed-in-part, and remanded.