Ordinary data processing steps to achieve a desired result do not transform an otherwise abstract idea into a patent-eligible application under 35 U.S.C. § 101. Here, for example, a method of processing oil well drill state information was found to be patent-ineligible because the claims simply recited generic computer functions that amounted to nothing more than the goal of determining the state of an oil well operation. “[T]he claims of the … patent recite the what of the invention, but none of the how that is necessary to turn the abstract idea into a patent-eligible application.” It may therefore be best to draft data processing claims based on more specifically how the desired result is achieved.
Background / Facts: The patent being asserted here is directed to processes for determining the state of an oil well drill. The claims recite receiving and validating sensor data in order to determine whether the oil well drill is in a drilling, sliding, or bore hole conditioning state.
Issue(s): Whether the claims add anything more to the abstract idea of storing, gathering, and analyzing data to be patent-eligible under 35 U.S.C. § 101.
Holding(s): No. “[The patentee] does not and cannot argue that storing state values, receiving sensor data, validating sensor data, or determining a state based on sensor data is individually inventive. And none of [the] arguments show that some inventive concept arises from the ordered combination of these steps, which, even if true, would be unpersuasive given that they are the most ordinary of steps in data analysis and are recited in the ordinary order. While the specification arguably provides specific embodiments for the step of ‘automatically selecting one of the states as the state of the well operation,’ claim 1 recites none of those details. Instead, claim 1 simply recites generic computer functions that amount to nothing more than the goal of determining the state of an oil well operation. … [T]he claims of the … patent recite the what of the invention, but none of the how that is necessary to turn the abstract idea into a patent-eligible application.”