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Versata Development Group, Inc. v. SAP America, Inc.

Representative Claim

  1. A method for determining a price of a product offered to a purchasing organization comprising:arranging a hierarchy of organizational groups comprising a plurality of branches such that an organizational group below a higher organizational group in each of the branches is a subset of the higher organizational group;arranging a hierarchy of product groups comprising a plurality of branches such that a product group below a higher product group in each of the branches in a subset of the higher product group;storing pricing information in a data source, wherein the pricing information is associated, with (i) a pricing type, (ii) the organizational groups, and (iii) the product groups;retrieving applicable pricing information corresponding to the product, the purchasing organization, each product group above the product group in each branch of the hierarchy of product groups in which the product is a member, and each organizational group above the purchasing organization in each branch of the hierarchy of organizational groups in which the purchasing organization is a member;sorting the pricing information according to the pricing types, the product, the purchasing organization, the hierarchy of product groups, and the hierarchy of organizational groups;eliminating any of the pricing information that is less restrictive; and

    determining the product price using the sorted pricing information.

Posture:

Patentee appeal from PTAB final written decision (cancelling certain claims as unpatentable).

Abstract Idea: Yes

“Using organizational and product group hierarchies to determine a price is an abstract idea that has no particular concrete or tangible form or application. It is a building block, a basic conceptual framework for organizing information, similar to the claims involving collecting, recognizing, and storing data in Content Extraction and the claims in CyberSource.”

Something More: No

“Versata argues that its claims recite ‘a specific approach to determining the price of a product on a computer, using hierarchies so as to enable the desired benefit for the computing environment: fewer software tables and searches, leading to improvements in computer performance and ease of maintenance.’ Appellant’s Br. at 43–44. However, all of the parties—including Versata—recognize that these supposed benefits are not recited in the claims at issue.”

“The section 101 analysis applied by the PTAB was not legally erroneous under Mayo and Alice. And its underlying fact findings and credibility determinations are supported by substantial evidence in the record. See Microsoft Corp. v. Proxy-conn, Inc., Nos. 14–1542, –1543, 2015 WL 3747257, at *2 (Fed.Cir. June 16, 2015) (noting that as a general matter, we review the PTAB’s findings of fact for substantial supporting evidence in the record).”