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Stoneeagle Services v. Pay-Plus Solutions

Representative Claim

  1. A method of facilitating payment of adjudicated health care benefits to a health care provider comprising:

identifying the health care provider that renders medical services in anticipation of payment;

identifying a payer that has agreed to pay the health care provider on behalf of a patient subject to preselected conditions;

identifying an administrator that determines whether the medical services conducted by the service provider meet the preselected conditions by the payer, generates an explanation of benefits, and authorizes payment of the service provider for an authorized amount;

intercepting the explanation of benefits and payment information transmitted from the administrator to the health care provider;

acquiring a single-use, stored-value card account number and loading it with funds equal to the authorized amount;

merging the stored-value card account number, the authorized amount, a card verification value code, and an expiration date with the explanation of benefits into a computer-generated image file; and

transmitting the image file to the health care provider via a computer-implemented transmission.

Posture:

Defendant motion for summary judgment.

Abstract Idea: No

“The claims at issue seek to address a problem uniquely within the health care industry: “to reduce the cost and time associated with generating hard copy checks and sending them by mail to [a] health care provider[].” (Id.).

But, the relevant claims stand apart because (1) the claims are different enough in substance from the prior art and (2) the claims do not merely recite the performance of some prior art business practice. Instead, the claimed solution is necessarily rooted in computer technology in order to overcome a problem specifically arising in the realm of the health care industry. (See Doc. # 156 at 5). Likewise, the claims do not “simply instruct the practitioner to implement [an] abstract idea with routine, conventional activity.”

Something More: N/A

Although not necessary, the court continued with step 2 and found:

Similarly, as articulated by Plaintiff, the claims at issue “recite a ‘specific way’ medical benefits are paid by a particular class (third party payers) by incorporating elements from multiple sources (EOB information from the health care claims administrator and stored-value card account information from a stored-value card processor) to solve a problem faced by the health care industry.” (See Doc. # 156 at 17). Therefore, the Court finds that the asserted claims do not attempt to preempt “the payment to service providers by third party payers in all fields,” and do not seek to grant Plaintiff a monopoly over the relevant practice in the health care industry.