Claims related to a kind of “organizing human activity” (e.g., minimizing security risks during bingo ticket purchases) that can be “carried out in existing computers long in use” and/or “done mentally” are likely directed to an abstract idea under the first prong of the Alice test. It remains an open question, however, “whether a claimed invention requiring many transactions might tip the scales of patent eligibility.”
Background / Facts: The patents being asserted here are directed to computer-aided methods and systems for managing the game of bingo. Generally, the claims recite storing a player’s preferred sets of bingo numbers; retrieving one such set upon demand, and playing that set; while simultaneously tracking the player’s sets, tracking player payments, and verifying winning numbers.
Issue(s): Whether claims directed to managing a bingo game while allowing a player to repeatedly play the same sets of numbers in multiple sessions are drawn to patent-eligible subject matter.
Holding(s): No. “[M]anaging the game of bingo consists solely of mental steps which can be carried out by a human using pen and paper. … Like the claims at issue in Benson, not only can these steps be ‘carried out in existing computers long in use,’ but they also can be ‘done mentally.’” Moreover, the claims here are “similar to the kind of ‘organizing human activity’ at issue in Alice.” Although the patents “are not drawn to the same subject matter at issue in Bilski and Alice, these claims are directed to the abstract idea of ‘solv[ing a] tampering problem and also minimiz[ing] other security risks’ during bingo ticket purchases,” which is “similar to the abstract ideas of ‘risk hedging’ during ‘consumer transactions’ [] and ‘mitigating settlement risk’ in ‘financial transactions’ [] that the Supreme Court [has] found ineligible.” Finally, the court noted that “[t]he system claims recite the same basic process as the method claims.”