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Clarilogic v. Formfree Holdings

Representative Claim

1. A computer-implemented method for providing certified financial data indicating financial risk about an individual, comprising:

(a) receiving a request for the certified financial data;

(b) electronically collecting financial account data about the individual from at least one financial source,

(c) transforming the financial account data into a desired format;

(d) validating the financial account data by applying an algorithm engine to the financial account data to identify exceptions, wherein the exceptions indicate incorrect data or financial risk;

(e) confirming the exceptions by collecting additional data and applying the algorithm engine to the additional data,

(f) marking the exceptions as valid exceptions when output of the algorithm engine validates the exceptions; and

(g) generating, using a computer, a report from the financial account data and the valid exceptions,

wherein the financial account data comprises at least one of real-time transaction data, real time balance data, historical transaction data, or historical balance data; and the algorithm engine identifies a pattern of financial risk; the method is computer implemented, and steps (c), (e), and (f) are executed via the computer or a series of computers.

Posture:

Appeal from the United States District Court for the Southern District of California in No. 3:15-cv-00041-DMSNLS, Judge Dana M. Sabraw.

Abstract Idea: Yes

The Federal Circuit agreed with the district court’s Step One determination, stating:

‘We find that claim 1 of the ’243 patent is directed to the abstract idea of gathering financial information of potential borrowers. When ‘the focus of the asserted claims’ is ‘on collecting information, analyzing it, and displaying certain results of the collection and analysis,’ the claims are directed to an abstract idea. Elec. Power Grp., LLC v. Alstom S.A., 830 F.3d 1350, 1343 (Fed. Cir. 2016). Peculiar to this case is that the algorithm engine mentioned in the claim is not claimed, identified, or explained. To be sure, claiming an algorithm does not alone render subject matter patent eligible. See Gottschalk v. Benson, 409 U.S. 63, 71–72 (1972). But a method for collection, analysis, and generation of information reports, where the claims are not limited to how the collected information is analyzed or reformed, is the height of abstraction.’

Something More: No

The Federal Circuit also agreed with the district court’s Step Two determination, stating:

“Here, as in Electric Power Group, the claims require only off-the shelf, conventional computer technology for gathering, analyzing, and displaying the desired information. 830 F.3d at 1355. Even if the ’243 patent may be said to invoke internet-based systems to increase speed, as FormFree argues, this does not make the claimed invention patent eligible. Id. at 1355–56. The ’243 patent does not claim the technical manner in which financial data is gathered, analyzed, or output. It does not claim any proprietary risk-assessment algorithm. The claims of the ’243 patent therefore do not clear Alice step two.”