Operations that can be performed by humans without a computer are generally directed to an abstract idea despite any further recitation of computer hardware. Here, for example, a method of anonymously evaluating a potential borrower for a loan using a third-party intermediary was found to be directed to an abstract idea because all the steps could be performed by humans without a computer, even though the method was recited as being performed on a computer. “[C]omputational methods which can be performed entirely in the human mind are the types of methods that embody the ‘basic tools of scientific and technological work’ that are free to all men and reserved exclusively to none.” It may therefore be best to craft business method applications around one of the acceptable categories of computer-implemented inventions positively outlined in this opinion, including “improv[ing] the functioning of the computer itself or effect[ing] an improvement in any other technology or technical field,” “solv[ing] a problem unique to the Internet,” or something “adequately tied to ‘a particular machine or apparatus.’”
Background / Facts: The patents being asserted here are directed to “financial transactions including a method for a borrower to evaluate and/or obtain financing, e.g., a loan.” The claims recite a “computer implemented system” comprising an “interface,” “network,” and “database” in which a borrower applies for a loan, a third party calculates the borrower’s credit grading, lenders provide loan pricing information to the third party based on the borrower’s credit grading, and only thereafter (at the election of the borrower) the borrower discloses its identity to a lender.
Issue(s): Whether the claims are patent-eligible under 35 U.S.C. § 101.
Holding(s): No. “The claim limitations, analyzed individually and ‘as a whole’ [], recite nothing more than the collection of information to generate a ‘credit grading’ and to facilitate anonymous loan shopping.” In particular, “[t]he series of steps covered by the asserted claims … could all be performed by humans without a computer.” Although the claims add “generic computer components such as an ‘interface,’ ‘network,’ and ‘database,’” these “generic computer components do not satisfy the inventive concept requirement.” “Nothing in the asserted claims ‘purport[s] to improve the functioning of the computer itself’ or ‘effect an improvement in any other technology or technical field.’ [] Nor do the claims solve a problem unique to the Internet. [] In addition, the claims are not adequately tied to ‘a particular machine or apparatus.’”