This case reinforces the unfortunate reality that there is simply no bright line rule in determining patent eligibility of computer-implemented inventions. Instead, the court seems fixated on whether the computer limitations play a “significant part” in the performance of the claimed invention. It appears that, in general, improvements to computer technologies themselves are patentable while the mere implementation of an idea via a computer is not, unless (as in CLS) it plays a significant part in permitting the claimed invention to be performed. This is sadly but clearly a blurry line. As an interesting ancillary issue, the court took time to note that claim format is not dispositive of the issue – a machine, system, medium, or the like may in some cases be equivalent to an abstract mental process for purposes of patent ineligibility.
Background / Facts: This is the complimentary case to CLS v. Alice from two weeks ago with regard to the question of patent eligibility under 35 U.S.C. § 101 of an invention implemented by computers. The asserted patents disclose specific formulae for determining the values required to manage a stable value protected life insurance policy. Independent claim 9, for example, is directed to “[a] method for managing a life insurance policy on behalf of a policy holder,” comprising the basic steps of generating a life insurance policy, calculating and storing various information units, determining various investment values, and so on.
Issue(s): Whether using a computer merely to facilitate complex calculations makes the computer sufficiently integral to the claimed invention so as to transform an otherwise patent-ineligible process into an eligible one.
Holding(s): No. The computer required by Bancorp’s claims is employed only for its most basic function, the performance of repetitive calculations, and as such does not impose meaningful limits on the scope of those claims. The court found no material difference between the claims invalidated in Bilski and those at issue here. The claims merely employ computers to track, reconcile, and administer a life insurance policy with a stable value component – i.e., the computer simply performs more efficiently what could otherwise be accomplished manually. Since basic digital computation is, in the court’s opinion, effectively “interchangeable” with certain mental processes, the use of a computer in an otherwise patent-ineligible process for no more than its most basic function – making calculations or computations – fails to circumvent the prohibition against patenting abstract ideas and mental processes.