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Mitchell International, Inc. v. Audatex North America, Inc. (CBM 2014-00174)

Representative Claim

  1. A method for obtaining an automobile insurance claim valuation report, comprising:
    receiving a uniform resource locator over an electronic communication network from a client computer;
    providing a web site that corresponds to the uniform resource locator, the web site provides at least one web page that relates to an insurance claim for a damaged vehicle;
    receiving data relating to the insurance claim;
    processing at a server the received data to automatically generate a valuation report for the damaged vehicle; and,
    transmitting the valuation report to the client computer over the electronic communication network through the web site.

Posture:

Institution of Covered Business Method Patent Review.

Abstract Idea: Yes

“On this record, we are persuaded that, similar to the concept of intermediated settlement in Alice and the concept of risk hedging in Bilski, the concept at issue here–obtaining a vehicle valuation report–is “a fundamental economic practice long prevalent in our system of commerce,” and “squarely within the realm of ‘abstract ideas.”’ Alice, 134 S. Ct. at 2356-57; Bilski, 130 S. Ct. 3218. Accordingly, we determine that Petitioner has demonstrated sufficiently that the challenged claims are directed to a patent-ineligible abstract idea.”

Something More: No

“Simply utilizing a generic wireless networked computer system to generate a vehicle valuation report faster and more efficiently is not enough, however, to transform a patent-ineligible claim into a patent-eligible invention. … At most, the computer implementation involved in the claims at issue here is an attempt to limit use of the abstract concept to a particular technological environment. Claims that simply instruct the practitioner to implement the abstract idea with routine, conventional activity do not transform an abstract idea into patent eligible subject matter. Ultramercial, 772 F.3d at 716. Claim 1 simply instructs the practitioner to use the internet to obtain a vehicle valuation, without reciting further, unconventional, features of that system.”

Additional Information:

“On this record, we are persuaded that, similar to the concept of intermediated settlement in Alice and the concept of risk hedging in Bilski, the concept at issue here–obtaining a vehicle valuation report–is “a fundamental economic practice long prevalent in our system of commerce,” and “squarely within the realm of ‘abstract ideas.”’ Alice, 134 S. Ct. at 2356-57; Bilski, 130 S. Ct. 3218. Accordingly, we determine that Petitioner has demonstrated sufficiently that the challenged claims are directed to a patent-ineligible abstract idea.”

“Here, we observe that each challenged claim, as a whole, is directed to the fundamental concept of providing a vehicle valuation. Patent Owner, while arguing that a person cannot provide at least one web page that relates to an insurance claim, has not at this stage in the proceeding asserted that the claims are directed to a specific implementation of computer systems. The only technological features recited in the claims are a generic computer implementation system performing generic computer functions. Specifically, the steps and calculations covered by the claims essentially require determining the value of a damaged vehicle; a calculation that can be performed by the human mind, or with the aid of pencil and paper..”

“Simply utilizing a generic wireless networked computer system to generate a vehicle valuation report faster and more efficiently is not enough, however, to transform a patent-ineligible claim into a patent-eligible invention. See Bancorp Servs. LLC v. Sun Life Assurance Co. of Canada, 687 F.3d 1266, 1279 (Fed. Cir. 2012) (finding a claim not patent-eligible when “the computer simply performs more efficiently what could otherwise be accomplished manually”); SiRF Tech., Inc. v. Int’l Trade Comm’n, 601 F.3d 1319, 1333 (Fed. Cir. 2010) (“In order for the addition of a machine to impose a meaningful limit on the scope of a claim, it must play a significant part in permitting the claimed method to be performed, rather than function solely as an obvious mechanism for permitting a solution to be achieved more quickly . . . .”). Nearly every computer has the capability of performing the basic calculation, storage, and transmission functions. See Alice, 134 S. Ct. at 2360. At most, the computer implementation involved in the claims at issue here is an attempt to limit use of the abstract concept to a particular technological environment. Claims that simply instruct the practitioner to implement the abstract idea with routine, conventional activity do not transform an abstract idea into patent eligible subject matter. Ultramercial, 772 F.3d at 716. Claim 1 simply instructs the practitioner to use the internet to obtain a vehicle valuation, without reciting further, unconventional, features of that system.”

“In the context of patent-eligible subject matter, we discern no meaningful distinction between independent claim 1, a method claim, and independent claims 10, 18, and 25, drawn to a system, server, and a computer program storage medium, respectively, as those claims simply recite the same functions as the process steps of claim 1.”