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In re Mario Villenna

Representative Claim

57. A system for distributing real-estate related information, comprising:
one or more computers configured to:
receive user-provided information and determine a geographic region based on received user-provided information;
produce a plurality of automated valuation method (AVM) values using residential property information, the residential properties being within the geographic region, the AVM values reflecting current market estimates for the residential properties;
provide display information to a remote terminal over a publicly accessible network based on the user-provided information, the display information enabling the remote terminal to generate a map-like display for the geographic region, the map-like display containing at least:
respective icons for each of a plurality of residential properties within the geographic region, the icons being spatially distributed relative to one another based on geographic information also residing in one or more computer-readable mediums; and
an AVM value for at least one of the plurality of residential properties within the map-like display, wherein each AVM value is pre-process such that an AVM value for the at least one residential property pre-exists before a user query of the respective property is performed,
and wherein the one or more computers update each of the AVM values without requiring a user query.

Posture:

Appeal from the United States Patent and Trademark Office, Patent Trial and Appeal Board in Application No. 13/294,044.

Abstract Idea: Yes

The Federal Circuit confirmed the PTAB’s Step One determination that “claim 57 is directed to an abstract idea—specifically, a fundamental economic practice.” In explanation, the opinion states:

“Claim 57 merely recites the familiar concept of property valuation. . . . Applicants’ claims recite one or more computers configured to receive a user’s target geographic region, produce property valuations, and display that information. Like the risk hedging in Bilski and the concept of intermediated settlement in Alice, the concept of property valuation, that is, determining a property’s market value, is ‘a fundamental economic practice long prevalent in our system of commerce.’ Id. (quoting Bilski, 561 U.S. at 611). Prospective sellers and buyers have long valued property and doing so is necessary to the functioning of the residential real estate market. As such, claim 57 is directed to the abstract idea of property valuation.”

 

Something More: No

The Federal Circuit also confirmed the PTAB’s Step Two determination that “claim 57 does not contain an inventive concept sufficient to ‘transform the nature of the claim’ into a patent-eligible application.” In explanation, the opinion states:

“The elements of claim 57 simply recite an abstract idea executed using computer technology, such as ‘one or more computers’ and a ‘remote terminal’ on a ‘publicly accessible network.’ . . . Claim 57 recites the basic steps of receiving user input, producing property valuations, and providing display information. This is a classic case of implementing an abstract idea on a computer, which is not eligible under Alice. Id. at 2358. Nor do the preprocessing limitations in the claim add anything more to make the claims eligible. Rather, the pre-processing limitations are directed to using a computer to perform routine computer activity.”