Processing information from specific hardware beyond a generic computer is still not sufficient to escape the realm of abstract ideas for the purposes of establishing subject matter eligibility under 35 U.S.C. § 101. Here, for example, claims directed to an ATM processing a stream of bits corresponding to data written on a scanned check was still found to be an abstract idea because it involved nothing more than data recognition and storage. “Similar to how the computer-implemented claims in Alice were directed to ‘the concept of intermediated settlement’ [] and the claims in Dealertrack were directed to the concept of ‘processing information through a clearinghouse’ [], [the patentee’s] claims are drawn to the basic concept of data recognition and storage.” It may therefore be best and perhaps necessary to craft data recognition claims not around the end result of automation via computers but around the technical details of how the automation can be achieved by overcoming conventional limitations of the computers themselves (e.g., the inability to parse out specific fields of a check).
Background / Facts: The patents being asserted here are directed to software on an automated teller machine (ATM) that recognizes information written on a scanned check, such as the check’s amount, and populates certain data fields with that information in a computer’s memory. In this regard, the claims generally recite a method of (1) extracting data from hard copy documents using an automated digitizing unit such as a scanner, (2) recognizing specific information from the extracted data, and (3) storing that information in a memory.
Issue(s): Whether the claims are distinguishable for subject matter eligibility purposes from those found to be abstract in Alice and other cases because they require not only a computer but also an additional machine—a scanner.
Holding(s): No. “Applying Mayo/Alice step one, we agree with the district court that the claims of the asserted patents are drawn to the abstract idea of 1) collecting data, 2) recognizing certain data within the collected data set, and 3) storing that recognized data in a memory. … [The patentee] argues that its claims are not drawn to an abstract idea because human minds are unable to process and recognize the stream of bits output by a scanner. [] However, the claims in Alice also required a computer that processed streams of bits, but nonetheless were found to be abstract. [] Similar to how the computer-implemented claims in Alice were directed to ‘the concept of intermediated settlement’ [] and the claims in Dealertrack were directed to the concept of ‘processing information through a clearinghouse’ [], [the patentee’s] claims are drawn to the basic concept of data recognition and storage.” With regard to Mayo/Alice step two, the court found that “[a]t most, [the patentee’s] claims attempt to limit the abstract idea of recognizing and storing information from hard copy documents using a scanner and a computer to a particular technological environment. Such a limitation has been held insufficient to save a claim in this context.”