“While it is commendable that the claimed automation leads to the expected improvements in speed, accuracy and completeness, University of Florida Research Foundationthe inherent advantage of automation is[] Don’t be less abstract. – Judge Cunningham, Federal Circuit
On April 7, the United States Court of Appeals for the Federal Circuit (CAFC) issued its judgment. People Eye Co., Ltd. v.Clear Co., Ltd. We affirm the decision on the petition to invalidate the patent infringement claims asserted by People.ai in the Northern District of California. We concurred with the district court that People.ai’s patent claims are directed to an abstract idea that is not patentable under 35 USC § 101. Differs from long-standing manual practices in record keeping.
Judge Alsup: Patent Claims Cover Long Commercial Practices
A ruling on a petition filed by U.S. District Judge William H. Alsup in the Northern California District Court found that all seven patents asserted by People.ai in the infringement action were subject matter not covered by patents under section 101. recognized as directed. US Patent No. 10922345, US Patent No. 10922345, Systems and methods for filtering electronic activity by analyzing current and past electronic activity; U.S. Patent No. 10565229; Systems and methods for direct reconciliation of electronic activity to record objects in Systems of Recordand U.S. Patent No. 10657129, Systems and methods for matching electronic activity to node profiles for recording objects in Systems of Record.
These patents claim techniques for automating the management of systems of record within customer relationship management (CRM) systems and other enterprise-level systems, addressing problems that can arise from manual data entry. I’m here. More specifically, the claim is directed to methods and systems for linking electronic activities such as emails and phone calls to record objects in a system of record that tracks customer information and salesperson communications.
Judge Alsup held that these and other People.ai patents allude to common business practices humans have long engaged in, including the typical activities of a corporate salesperson. , was invalid. After discovering that People.ai’s patent claims were directed to unpatentable subject matter, Alice/Mayo In the Section 101 Validity Framework, Judge Alsup further found that the asserted claims lacked an inventive concept in Step 2. Alice/Mayo.
Advantages of automation do not reduce abstractness of claims
Reconsideration of the Claims of the ‘345 Patent againSimilar to the Ninth Circuit’s standard of review for judgments on complaints, the Federal Circuit ruled that claims 11 and 18, appealed by People.ai, “restrict certain data from further analysis based on various generic sets.” I decided that it was directed to an abstract idea. Rules. As pointed out by the Federal Circuit, the data filtering method of claim 11 of the ‘345 patent operates on his three types of filtering rules: A regular expression pattern policy that identifies electronic activity using strings that match the regular expression pattern. A logic-based policy that identifies electronic activities according to the participants in the activity. The Federal Circuit has determined that the salesperson has long applied each of these types of filtering his policies in the course of the company’s business. “For example, a ‘logic-based policy’ is used by a salesperson who chooses not to send emails from her spouse to her CRM,” Judge Cunningham wrote.
Following its own recent case law on section 101 patent validity, the Federal Circuit found that the 2016 decision was Intellectual Ventures I LLC v. Symantec Corp. Especially related to the appeal of People.ai.of Symantecthe Federal Circuit found that a patent claim covering a method of filtering e-mail to remove spam e-mail and prevent the transmission of viruses via e-mail was directed to an abstract idea not subject to patentability. In that case, the Federal Circuit applied the claimed technology to the long-established practice of filtering unwanted envelopes from paper mailers based on the characteristics of discarded mail. It was likened to the practice of
“like Symantecas required by the claims of the ‘345 patent, it has long been unacceptable for a sales representative receiving a communication to set aside certain communications and file or further process other communications based on their characteristics. It was common practice…the automation claimed was laudable for its speed, accuracy and completeness, but University of Florida Research Foundationthe inherent advantage of automation is[] Don’t abstract it.
People.ai argued on appeal that the ‘345 patent’s claims are distinct from the invalidated claims. Symantec This is because the rule-based approach to filtering was fundamentally different from the subjective, manual approach that humans have traditionally used. However, unlike the patent claims upheld by the Federal Circuit, Macro v. Namco Bandai Games America (2016) and Finjan v. Blue Coat Systems (2018), the procedure claimed by the People.ai patent did not improve the basic functionality of the computer performing the procedure.in further contrast to macro, People.ai’s patent claims did not claim methods different from those traditionally used long before computer technology was applied. The Federal Circuit ruled that after “removing steps not required by the claims,” he had only three remaining steps. Select rule-based filtering policies according to sender and recipient accounts. Apply policies to assess whether communications should be logged as related to a particular sales opportunity.
No original concept in remote storage or matching policy
in step 2 of Alice/Mayo, the Federal Circuit held that the ‘345 patent’s claims lacked an inventive concept. “Our conclusions were confirmed by People.ai identifying the claimed benefits of the claimed claims, avoiding the pitfalls of manually entering data using a computer.” ‘ wrote Judge Cunningham. People.ai argued that the “node profile” of Claim 18 was a unique feature not replicated in a brick-and-mortar mailroom, but the Federal Circuit instead held that the claimed architecture, as construed by the district court, was: We have determined that it is not functionally different from the electronic system. A rolodex or filing cabinet used to store business documents and other records.
It differs from the patent claims that the Federal Circuit upheld in Step 2 in the following cases: BASCOM Global Internet Services v. AT&T Mobility (2016), a patent claim directed to the abstract idea of filtering internet content included the inventive concept of installing a customizable filtering tool remote from the end user. People.ai’s patent claims that the automation proposed in the ‘345 patent and the benefits cited are just what one would expect from automation. ”
The Federal Circuit’s decision expedited People.ai’s arguments regarding the ‘229 and ‘129 patents, both of which contain similar claims to the ‘345 patent. People.ai argued that the ‘229 patent claimed data storage on a local processor external to the CRM, but even assuming such storage was required by the claims, the Federal Circuit determined that the underlying idea claimed by the ‘229 patent was still abstract. Regardless of where the association is stored. Finally, the Federal Circuit has found that the matching policy claimed in the ‘129 patent has long been used in corporate mailrooms to organize communications by sender and recipient.
