“[T]he well-known concept of categorical data storage, i.e., the idea of collecting information in classified form, then separating and transmitting that information according to its classification, is an abstract idea that is not patent-eligible.” The fact that a method may require use of a machine to collect or disseminate such data, and hence, cannot be literally performed in the human mind alone, is not by itself sufficient to remove it from the realm of abstract ideas. “Although methods that can be performed in the human mind alone are not eligible for patent protection, … the category of patent-ineligible abstract ideas is not limited to methods that can be performed in the human mind.” Moreover, a computing machine such as a “telephone,” when described generically in the specification as a range of different machines, including “a conventional telephone,” “a portable telephone,” and “a battery operated portable device which is a cross between a laptop computer and a cellular telephone,” does not by itself, in the words of Mayo, “add enough” to “tie down the claim so that, in practical terms, it does not cover the full abstract idea itself.”
Background / Facts: The patent being asserted here is directed to methods and systems for capturing and storing data. Claim 1 recites steps of (1) “obtaining data transaction information entered on a telephone from a single transmission from said telephone;” (2) “forming a plurality of different exploded data transactions … formed based on said data transaction information from said single transmission, so that different data from the single data transmission is separated and sent to different destinations;” and (3) “sending said different exploded data transactions … to said different destinations, all based on said data transaction information entered in said single transmission.” In the words of the court, “[t]hese steps require obtaining data, ‘exploding’ the data, i.e., separating it into component parts, and sending those parts to different destinations.”
Issue(s): Whether claims defined as using a telephone to perform a series of data categorization and storage steps are subject matter eligible under 35 U.S.C. § 101.
Holding(s): No. “We agree with the district court that the … patent involves an abstract idea, as in Bilski. Like protecting against risk, using categories to organize, store, and transmit information is well-established. Here, the well-known concept of categorical data storage, i.e., the idea of collecting information in classified form, then separating and transmitting that information according to its classification, is an abstract idea that is not patent-eligible.” While acknowledging that “[f]inding the abstract idea itself to be ineligible subject matter is not the end of the inquiry,” the court found that “[t]he ‘telephone’ recited in claim 1 is not a specific machine, and adds nothing of significance to the claimed abstract idea.” Thus, “[a]s in Mayo, the ‘ordered combination adds nothing’ because it follows from the underlying idea of categorical information storage.”