Search Team

Search by Last Name
A
B
C
D
E
F
G
H
I
J
K
L
M
N
O
P
Q
R
S
T
U
V
W
X
Y
Z

Innovation Scis., LLC v. Amazon.com, Inc.

Representative Claim

17. An online method for a payment server to support online buying over the Internet, the online method comprising:
receiving, at the payment server, credit card payment information transmitted from a buyer for payment of one or more items identified for purchase from a website listing the items, wherein the credit card payment information is received after online communication of the buyer has been switched from the website listing the items to a website supported by the payment server, wherein the switching of the online communication of the buyer is after an indication from the buyer to buy the one or more of the items;
sending the credit card payment information to an established financial channel;
receiving a credit card payment processing decision from the established financial channel; and
sending credit card payment confirmation information;
wherein:
transmission of information about the items for purchase between a server supporting the website listing the items and the buyer, before occurrence of the indication to buy, is less secure than transmission, from the buyer, of the credit card payment information, the transmission of the credit card payment information being performed under a security protocol for encryption of the credit card payment information, said security protocol providing at least 128 bit encryption for the credit card payment information;
the payment server has a respective IP address different from a respective IP address of the server supporting the website listing the items;
the sending of the credit card payment confirmation information updates the server supporting the website listing the items, with respect to the purchase of the one or more items identified by the buyer, in support of a real-time purchasing/sales environment on the website listing the items;
the server supporting the website listing the items is in one of a first nation state or a second nation state; and
the payment server is in the first nation state.

Posture:

Appeal from the United States District Court for the Eastern District of Virginia in No. 1:16-cv-00861-LO-MSN, Judge Liam O’Grady.

Abstract Idea: Yes

The Federal Circuit found the claim at issue directed to the abstract idea of securely processing a credit card transaction with a payment server. The claim recited, in functional, result-oriented terms, receiving credit card payment information at a server different from the server on which the item for purchase is listed, sending the payment information “to an established financial channel,” receiving a “processing decision” from that channel, sending payment confirmation, and updating the server supporting the website listing the item that the item was purchased. The Federal Circuit found that even though communication was “switched” from a website hosted on one server to a website hosted on another server with better security, that did not mean the invention was directed to “a specific improvement in the capabilities of computing devices.” In particular, the invention did not purport to improve the payment server or the server on which the item for purchase is listed and instead claimed the idea of switching to a more secure server for payment processing, where the specification did not recite any specific way to carry out such a switch.

Something More: No

The patent owner argued that the “switching” limitation was an inventive concept, but the Federal Circuit disagreed. The Federal Circuit held the claimed steps beginning with the transmission of the credit card payment information through the completion of the purchase were the same as those used in “a conventional Internet transaction system having adequate credit card information security,” as the specification admitted. Moreover, switching from a less secure server to a more secure server similarly did not provide an inventive concept. The claim sought to capture the broad concept of switching to a more secure server, rather than a specific way to do so.