In its first ruling under the newly implemented American Invents Act (AIA) Transitional Program for Covered Business Method Patents, the Patent Trial and Appeal Board (PTAB) invalidated Versata’s 6,553,350 (‘350) patent. In reaching its decision, the PTAB confirmed use of the broadest reasonable interpretation (BRI) standard for claim construction in AIA Transitional Program for Covered Business Method Patents. Using this standard for claim construction, the PTAB invalidated all challenged claims, finding the claims recited an unpatentable abstract idea—namely, the abstract idea of “determining a price using organizational and product group hierarchies, which are akin to management organizational charts.” The challenged claims did not incorporate sufficient meaningful limitations, and the PTAB emphasized that “claims do not become patentable under § 101 simply for reciting a computer element.”
- The claims had no substantial practical application except in connection with a computer. In particular, the claims were drafted to include computer hardware limitations, but the underlying process could be performed with pen and paper.
- The claims required only general purpose computer hardware and programming to implement each method step. The ’350 patent specifically stated that the invention could be implemented in any type of computer system or processing environment. “[T]he recitation of generic general purpose computer hardware (processor, memory, storage) in the challenged claims represents routine, well-understood conventional hardware that fails to narrow the claims relative to the abstract idea.”
- The storing, retrieving, sorting, eliminating, and determining steps and their interrelation with each other and the arranging steps were merely routine, conventional steps. The steps did not reflect meaningful limitations.