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Content Extraction & Transmission LLC v. Wells Fargo Bank, N.A.

Representative Claim

‘855 Patent:

  1. A method of processing information from a diversity of types of hard copy documents, said method comprising the steps of:

(a) receiving output representing [*3]  a diversity of types of hard copy documents from an automated digitizing unit and storing information from said diversity of types of hard copy documents into a memory, said information not fixed from one document to the next, said receiving step not preceded by scanning, via said automated digitizing unit, of a separate document containing format requirements;

(b) recognizing portions of said hard copy documents corresponding to a first data field; and

(c) storing information from said portions of said hard copy documents corresponding to said first data field into memory locations for said first data field.

Posture:

Appeals from the United States District Court for the District of New Jersey in Nos. 12–CV–2501, 12–CV–6960, and 12–CV–7640, Judge Michael A. Shipp, who granted of motion to dismiss under Rule 12(b)(6) of the FRCP.

Abstract Idea: Yes

“[W]e agree with the district court that the claims of the asserted patents are drawn to the abstract idea of 1) collecting data, 2) recognizing certain data within the collected data set, and 3) storing that recognized data in a memory. The concept of data collection, recognition, and storage is undisputedly well-known. Indeed, humans have always performed these functions.”

Something More: No

“[W]e agree with the district court that the asserted patents contain no limitations—either individually or as an ordered combination—that transform the claims into a patent-eligible application….[The] claims merely recite the use of this existing scanning and processing technology to recognize and store data from specific data fields such as amounts, addresses, and dates. There is no ‘inventive concept’ in CET’s use of a generic scanner and computer to perform well-understood, routine, and conventional activities commonly used in industry.” (internal citations omitted).