The use of conventional technology in a well-known environment that does not address any problems presented by the conventional technology is generally directed to an abstract idea under step one of the Mayo/Alice framework. Here, for example, attaching classification data, such as dates and times, to images for the purpose of storing those images in an organized manner was found to be a well-established “basic concept” sufficient to fall under step one of the Mayo/Alice framework because it did not address a specific improvement to computer functionality such as any problems presented by combining a camera with a cellular telephone. “We [have] contrasted claims ‘directed to an improvement in the functioning of a computer’ with claims ‘simply adding conventional computer components to well-known business practices,’ or claims reciting ‘use of an abstract mathematical formula on any general purpose computer,’ or ‘a purely conventional computer implementation of a mathematical formula,’ or ‘generalized steps to be performed on a computer using conventional computer activity.’” This would be a good case to consult before responding to a subject matter eligibility rejection asserting an abstract idea for computer-related inventions.
Background / Facts: The patent being asserted here is directed to a method and system for taking, transmitting, and organizing digital images. The claims recite manually or automatically assigning “classification data,” such as a date or timestamp, to digital images and sending those images to a server. While the claims require concrete, tangible components such as “a telephone unit” and a “server,” the specification describes the recited physical components as merely providing a generic environment in which to carry out the classifying and storing of digital images in an organized manner.
Issue(s): Whether the claims as a whole are drawn to more than the concept of classifying an image and storing the image based on its classification under Alice step 1.
Holding(s): No. “Contrary to [the patentee’s] arguments on appeal, the claims here are not directed to a specific improvement to computer functionality. Rather, they are directed to the use of conventional or generic technology in a nascent but well-known environment, without any claim that the invention reflects an inventive solution to any problem presented by combining the two. According to the [] patent, the problem facing the inventor was not how to combine a camera with a cellular telephone, how to transmit images via a cellular network, or even how to append classification information to that data. Nor was the problem related to the structure of the server that stores the organized digital images. Rather, the inventor sought to ‘provid[e] for recording, administration and archiving of digital images simply, fast and in such way that the information therefore may be easily tracked.’ … For these same reasons, the claims are not directed to a solution to a ‘technological problem.’” Thus, “attaching classification data, such as dates and times, to images for the purpose of storing those images in an organized manner is a well-established ‘basic concept’ sufficient to fall under Alice step 1.”