Computer-implemented data processing to achieve super-human results does not constitute an inventive concept under Alice/Mayo step two. Here, for example, a computer-implemented business method for processing certified payroll records was found to lack an inventive concept under Alice/Mayo step two even though it was acknowledged that a human could not easily perform the steps claimed. “[R]elying on a computer to perform routine tasks more quickly or more accurately is insufficient to render a claim patent eligible.” It may therefore be best to avoid arguing that a data processing invention is patent eligible because it cannot be performed by a human.
Background / Facts: The patent being asserted here is directed to a computer-implemented business method for processing certified payroll records (CPRs). The claims recite a method of processing payroll such that CPRs for different jurisdictions are generated “in conjunction with and simultaneous with core payroll processing.” It is not disputed that the claims are directed to an abstract idea under step one of the Alice/Mayo inquiry.
Issue(s): Whether the generation of CPRs “in conjunction with and simultaneous with” core payroll processing constitutes an Alice/May step-two inventive concept.
Holding(s): No. “As disclosed in the specification and recited in the plain claim language, the [] patent claims generating CPRs in conjunction with and simultaneous with core payroll processing simply by applying computer elements such as relational databases. … While it may be true that, as [the patentee] argues, a human could not easily process core payroll while simultaneously generating CPRs, ‘relying on a computer to perform routine tasks more quickly or more accurately is insufficient to render a claim patent eligible.’”