Search Team

Search by Last Name
A
B
C
D
E
F
G
H
I
J
K
L
M
N
O
P
Q
R
S
T
U
V
W
X
Y
Z

Kenexa Brassring, Inc. v. Hireability.com, LLC, et al.

Representative Claim

  1. (‘939 Patent) A method for facilitating the accurate transfer of information from each of a plurality of nonuniformly formatted source data streams into a structured database, said method comprising the steps of:

supplying digital data representing each of a plurality of source data streams from a plurality of users, each said source data stream containing data corresponding to multiple discernible source data strings;

processing said digital data for extracting selected ones of said source data strings and generating related target data strings;

displaying a structured form comprised of multiple fields, each field being capable of accommodating a data string and wherein one or more of said fields have said target data strings inserted within;

enabling each user to modify and/or accept said target data strings inserted within said displayed form corresponding to said source data stream originating from said user; and

storing data corresponding to said data strings from said form fields into a database.

Posture:

Rule 12(c) Motion for judgment on the pleadings.

Abstract Idea: Yes

As evidenced by defendants’ attempt to summarize the patents-in-suit, the claims here are not easily reduced to one succinct statement of an “abstract idea.” In that respect, they appear dissimilar to the patents invalidated in cases like Alice, 134 S. Ct. at 2355 (“intermediated settlement”) or Bilski, 561 U.S. at 612 (“hedging risk”). However, Alice made clear that the underlying principle behind both cases was that patents directed only to “organizing human activity” are invalid. Alice, 134 S. Ct. at 2356. That is precisely the apparent function of the patents-in-suit, which are directed toward streamlining the job-application process. . . .  Considering the patents-in-suit in light of those precedents, they may be directed toward an abstract idea.

Something More: Yes

Furthermore, the claims are not manifestly invalid for lack of inventiveness. Although simply reciting the use of “digital data,” without more, would not be sufficient to satisfy the “inventive concept” requirement, see id. at 2358 (“[T]he mere recitation of a generic computer cannot transform a patent-ineligible abstract idea into a patent-eligible invention.”), the claims also recite a method of digital extraction—that is, isolating certain input information from a resume and transferring it to a particular field in a job-application form. . . . [D]efendants have not put forth “clear and convincing evidence” that the patents-in-suit contain no limitations that are “sufficient to ensure that the patent in practice amounts to significantly more than a patent upon the [ineligible concept] itself.”