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BSG Tech v. BuySeasons

Representative Claim

1. A method of indexing an item on a database, comprising:

providing the database with a structure having a plurality of item classifications, parameters, and values, wherein individual parameters are independently related to individual item classifications, and individual values are independently related to individual parameters;

guiding the user in selecting a specific item classification for the item from the plurality of item classifications;

storing the item on the database as a plurality of user-selected item classification/parameter value combinations; and

guiding the user in selecting at least one of (a) the parameters of the combinations by displaying relative historical usage information for a plurality of parameters previously used by other users, and (b)  the values of the combinations by displaying relative historical usage information for a plurality of values previously used by other users.

Posture:

Appeal from U.S. Dist. Court’s (EDTX) Rule 56 dismissal holding claims patent ineligible under 35 U.S.C. § 101.

Abstract Idea: Yes

“We have consistently held . . . that claims are not saved from abstraction merely because they recite components more specific than a generic computer.” “Here, the recited database structure similarly provides a generic environment in which the claimed method is performed. The ’699 specification makes clear that databases allowing users to post parametrized items were commonly used at the time of invention.” “Thus, the recitation of a database structure slightly more detailed than a generic database does not save the asserted claims at step one.”

“In [Plaintiff]’s view, a claim is not directed to an abstract idea so long as it recites limitations that render it narrower than that abstract idea.” “[W]e have never suggested that such minimal narrowing, by itself, satisfies Alice’s test.” “[A] claim is not patent eligible merely because it applies an abstract idea in a narrow way. For an application of an abstract idea to satisfy step one, the claim’s focus must be something other than the abstract idea itself.”

“[Plaintiff] argues that the claimed invention improves the quality of information added to the database and the organization of information in the database.” “These benefits, however, are not improvements to database functionality. Instead, they are benefits that flow from performing an abstract idea in conjunction with a well-known database structure.” “The claims do not recite any improvement to the way in which such databases store or organize information . . . .” “[A]an improvement to the information stored by a database is not equivalent to an improvement in the database’s functionality.” “Thus, at step one, the ’699 patent claims are directed to the abstract idea of having users consider historical usage information while inputting data.”

Something More: No

“It has been clear since Alice that a claimed invention’s use of the ineligible concept to which it is directed cannot supply the inventive concept that renders the invention ‘significantly more’ than that ineligible concept.” “Here, the only alleged unconventional feature of [Plaintiff]’s claims is the requirement that users are guided by summary comparison usage information or relative historical

usage information. But this simply restates what we have already determined is an abstract idea.”

“[Plaintiff]’s remaining argument at step two is that the asserted claims supply an inventive concept because they require a specific database structure that does not preempt consideration of historical usage information while inputting data into other types of databases.” “While preemption concerns are ‘the basis for the judicial exceptions to patentability . . . ,’ the absence of complete preemption does not demonstrate patent eligibility.”