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Aatrix v. Green Shades Software

Representative Claim

  1. A data processing system for designing, creating, and importing data into, a viewable form viewable by the user of the data processing system, comprising:

(a) a form file that models the physical representation of an original paper form and establishes the calculations and rule conditions required to fill in the viewable form;

(b) a form file creation program that imports a background image from an original form, allows a user to adjust and test-print the background image and compare the alignment of the original form to the background test-print, and creates the form file;

(c) a data file containing data from a user application for populating the viewable form; and

(d) a form viewer program operating on the form file and the data file, to perform calculations, allow the user of the data processing system to review and change the data, and create viewable forms and reports.

Posture:

Appeal from U.S. Dist. Court’s (MDFL) Rule 12(b)(6) dismissal holding claims patent ineligible under 35 U.S.C. § 101.

Abstract Idea: Yes

As a preliminary matter, the district court erred to the extent it held that claim 1 of the ‘615 patent is ineligible solely because it is directed to an intangible embodiment. We have held that claims to pure data and claims to transitory signals embedded with data are directed to ineligible subject matter under § 101. Digitech Image Techs., LLC v. Elecs. for Imaging, Inc., 758 F.3d 1344, 1348-50 (Fed. Cir. 2014); In re Nuijten, 500 F.3d 1346, 1353-57 (Fed. Cir. 2007). But the rationale of those decisions—failure of the claimed matter to come within any of the four statutory categories: process, machine, manufacture, composition of matter—does not apply here.

[Step 1 not addressed directly.]

Something More: N/A

At least since the proposal of the second amended complaint, and perhaps even before, allegations as to facts and the proper construction of the claims have precluded the court’s conclusion that the claimed “data file” is “a `well understood’ and `routine’ component and function of a computer.” J.A. 26. The “data file” limitation may reflect, as Aatrix argues, an improvement in the importation of data from third-party software applications. Cf. Enfish,822 F.3d at 1337 (“Here, the claims are not simply directed to any form of storing tabular data, but instead are specifically directed to a self-referentialtable for a computer database.”). In light of the allegations made by Aatrix, the district court could not conclude at the Rule 12(b)(6) stage that the claimed elements were wellunderstood, routine, or conventional. Cf. Affinity Labs of Tex., LLC v. Amazon.com Inc., 838 F.3d 1266, 1270 (Fed. Cir. 2016) (rejecting criticism of conclusion that the claims recited “routine and generic processing and storing capabilities of computers generally” where it was not suggested those elements were new or inventive); Content Extraction, 776 F.3d at 1347 (noting the concept of “data collection, recognition, and storage is undisputedly well-known” (emphasis added)). Thus, allowing Aatrix to file the proposed amended complaint would not have been futile.