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Audatex North America v. Mitchell International

Representative Claim

30. A method for obtaining an automobile insurance claim valuation report of a damaged vehicle in association with the processing of an insurance claim, comprising:

transmitting a uniform resource locator over an electronic communication network from a client computer;

connecting with a web site that corresponds to the uniform resource locator, the web site provides a plurality of web pages that allows an operator to input data relating to an insurance claim for the damaged vehicle, the insurance claim being a request to recover market value or repair cost in association with an insurance policy;

entering data relating to the insurance claim;

providing a parts list and calculated estimate data through the web site;

processing the entered data to generate a valuation report for the damaged vehicle, the valuation report provides a market value for the damaged vehicle, before the damaged vehicle was damaged, based on factors including mileage, condition, and geographic location; and,

transmitting the valuation report to the client computer over the electronic communication network through the web site.

71. The method of claim 30, further comprising transmitting the valuation report from a valuation server to a web server before transmitting the valuation report to the client computer, the valuation report being generated by the valuation server with a database of vehicle values that is called by a first active server page, the parts list and calculated estimate data being provided by a program called by a second active server page.

Posture:

Appeals from the United States Patent and Trademark Office, Patent Trial and Appeal Board in Nos. CBM2014-00171, CBM2014-00173.

Abstract Idea: Yes

The Federal Circuit confirmed the Patent Trial and Appeal Board’s Step One determination that “the proposed claims are directed to the abstract idea of ‘providing a vehicle valuation through the collection and use of vehicle information.’” In explanation, the opinion states:

“Here, the proposed claims recite nothing more than the collection of information to generate a valuation report for a damaged vehicle with the aid of well-known technology. They are neither directed to an improvement in computer functionality, nor provide a specific improvement in the way computers operate. Cf. Enfish, 822 F.3d at 1336–37. Rather, they embody an abstract idea that merely uses a computer and generic components as tools to collect these data and generate reports. This is insufficient under step one.”

Something More: No

The Federal Circuit also confirmed the Patent Trial and Appeal Board’s Step Two determination that “the proposed claims fail step two as well” because (1) the claims neither improve the technological infrastructure nor provide solutions to challenges particular to the Internet; (2) the claims merely recite generic computer; and (3) when viewed as an ordered combination, the claims recite generic computer components used conventionally. In explanation, the opinion states:

“Here, the proposed claims neither improve the technological infrastructure nor provide solutions to challenges particular to the Internet. Rather, they add computer functionality and recite use of the Internet to increase the speed and efficiency of an abstract process. This is not enough. See Intellectual Ventures I LLC . . . ‘[M]erely adding computer functionality to increase the speed or efficiency of the process does not confer patent eligibility on an otherwise abstract idea.’ . . . ‘[T]he use of the Internet is not sufficient to save otherwise abstract claims from ineligibility under § 101.’). Further, the proposed claims merely recite a host of generic computer components. For example, claim 37, which incorporates claim 30, recites: ‘a web site,’ ‘web pages,’ ‘a client computer,’ ‘an electronic communication network,’ ‘a database,’ ‘a web server,’ and ‘a valuation server.’

[Patentee] relies heavily throughout its briefing on the two ASPs recited in claims 37 and 40. But [Patentee] itself concedes that it did not invent ASPs, . . ., and the claims do not recite them in a manner that produces ‘a result that overrides the routine and conventional’ use of these known features. . . . When viewed as an ordered combination, the proposed claims recite no more than the sort of ‘perfectly conventional’ generic computer components employed in a customary manner that we have held insufficient to transform the abstract idea into a patent-eligible invention.”