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Westlake Services, LLC v. Credit Acceptance Corp. (CBM2014-00176)

Representative Claim

  1. A method for providing a financing source to a customer to purchase a product selected from an inventory of products, the method comprising the steps of:
    receiving information related to a database of a dealer’s inventory, wherein the dealer’s inventory includes a plurality of products, each product having a dealer cost associated therewith and a sale price at which the dealer desires to sell the product;
    receiving information from the customer including a down payment amount which the customer has available for a down payment towards the purchase of a product;
    calculating a credit score for the customer based at least in part on the information gathered from the customer;
    determining an advance amount to be paid to the dealer from the financing source for each individual product in the dealer inventory in the event that that particular product is sold to the customer;
    calculating a front-end profit to be realized by the dealer for each individual product in the dealer inventory based on the dealer cost associated with each individual product, the advance amount determined for each individual product, and the down payment amount; and
    presenting a financing package to the dealer for each individual product in the dealer’s inventory for immediate offer for sale to the customer.

 

  1. The method of claim 1 further comprising the steps of: providing a user terminal for entering the customer information;
    providing a server connected to the user terminal via a network, and having access to the dealer inventory database; and
    configuring the server to receive the customer information from the user terminal, to access the dealer inventory database, to generate the financing packages for each individual product in the dealer’s inventory based on the customer information and the inventory data stored in the database, and to transmit the financial packages to the user terminal over the network for display on the user terminal.

Posture:

Petition CBM institution.

Abstract Idea: Yes

“In essence, claim 10 recites applying the abstract idea of claim 1 on a generic computer. This is analogous to the claims at issue in Alice, which generically recited a “data storage unit” and “computer,” for example, CLS Bank Int’l v. Alice Corp. Pty. Ltd., 717 F.3d 1269, 1285-90 (Fed. Cir. 2013), and those at issue in Accenture Global Servs., GmbH v. Guidewire Software, Inc., 728, F.3d 1336, 1344-45 (Fed. Cir. 2013), which recited a “database,” “client component,” “server component,” and “automated method,” for example.”

Something More: No

“Patent Owner further argues that the claims recite “specifically-configured computer components” that are “core limitations because they are necessary to effectively practice the invention.” Prelim. Resp. 18. We are not persuaded. Similar to the claims at issue in Alice, Ultramercial III, and Accenture, the computer components recited in the claims are recited functionally and generically, without any detail as to their configurations or implementations. Nor does Patent Owner point to anything in the Specification describing the configuration of the computer components in substantially more detail or explain why the claims would require such detail.”

Additional Information:

“Claim 1, at issue in CBM2014-00008, simply describes receiving information, including sale prices

and dealer costs, for items in a dealer’s inventory; receiving down payment information from a customer wishing to buy a product from the dealer; calculating a credit score for the customer; determining how much a financer will advance to the dealer (advance amount) for each product in the inventory; calculating profits for the inventory items (using basic arithmetic based on the advance amount, dealer cost, and down payment); and presenting financing packages (with unspecified information) to the dealer. As we explained in CBM2014-00008, the arguments and evidence presented by Petitioner persuaded us that this is no more than the abstract idea of processing an application for financing a purchase. ‘008 Dec. 18. Patent Owner’s arguments in this case do not persuade us otherwise.”

“Based on the current record, we are persuaded that the limitations to which Patent Owner refers simply ‘limit[] the use of an abstract idea to a particular technological environment,’ which is not, according to Alice, sufficient to impart patent eligibility.”