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Intellectual Ventures I LLC v. Erie Indemnity Co.

Representative Claim

The ’434 Patent

Claim 1. A method for creating a database and an index to search the database, comprising the steps of:

creating the index by defining a plurality of XML tags including domain tags and category tags;

creating a first metafile that corresponds to a first domain tag; and

creating the database by providing a plurality of records, each record having an XML index component.

Claim 19. A method for searching a database of information, comprising the steps of:

receiving a request for information from a client, the request having a first term;

identifying a first XML tag that is associated with the first term;

determining whether a first metafile corresponds to the first XML tag;

if the first metafile corresponds to the first XML tag, then transmitting the first XML tag, the first metafile and query code to the client;

once the client conducts a query by executing the query code using the first XML tag and the first metafile, then receiving query results including a first set of XML tags from the client;

combining the first set of XML tags into a key;

using the key to search the database to locate records including the first set of XML tags; and

delivering the records including the first set of XML tags to the client.

The ’002 Patent

Claim 40. A system for storing and accessing user specific resources and information, the system comprising:

a network for accessing the user specific resources and information stored in a network server; and

a local device communicating with the network and having a local memory and a mobile interface, wherein the local memory also includes user specific resources and information, and the mobile interface includes pointers corresponding to the user specific resources and information that are stored either on the local device or the network server, wherein the pointers provide links to access the corresponding user specific resources and information.

Posture:

Appeals from the United States District Court for the Western District of Pennsylvania in Nos. 1:14-cv-00220-MRH, 2:14-cv-01130-MRH, Judge Mark R. Hornak.

Abstract Idea: Yes

The ’434 patent

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

“Under step one, we agree with the district court that the invention is drawn to the abstract idea of ‘creating an index and using that index to search for and retrieve data.’ As the patent itself observes, the invention relates to ‘locating information in a database, and . . . using an index that includes tags and metafiles to locate the desired information.’ This type of activity, i.e., organizing and accessing records through the creation of an index-searchable database, includes longstanding conduct that existed well before the advent of computers and the Internet. For example, a hardcopy-based classification system (such as library-indexing system) employs a similar concept as the one recited by the ’434 patent. There, classifiers organize and cross-reference information and resources (such as books, magazines, or the like) by certain identifiable tags, e.g., title, author, subject. Here, tags are similarly used to identify, organize, and locate the desired resource.”

 The ’002 patent

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

“Thus, the mobile interface here does little more than provide a generic technological environment to allow users to access information. And as we have previously observed, ‘[a]n abstract idea does not become nonabstract by limiting the invention to a particular field of use or technological environment, such as the Internet.’ Intellectual Ventures I LLC v. Capital One Bank (USA), 792 F.3d 1363, 1366 (Fed. Cir. 2015). We conclude therefore that the ’002 patent’s concept of remotely accessing user-specific information is abstract, and thus fails under step one.”

Something More: No

The ’434 patent

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

“Evaluating the representative claims 1 and 19, we agree with the district court that they lack an ‘inventive concept’ that transforms the abstract idea of creating an index and using that index to search for and retrieve data into a patent-eligible application of that abstract idea. IV again argues that the claimed contribution lies in the utilization of an index constructed of specific XML tags and metadata to facilitate searches. But the recitation of an index employing XML tags to navigate a computerized database is simply not enough to transform the patent-ineligible abstract idea here into a patent-eligible invention. See Alice, 134 S. Ct. at 2357 (‘[C]laims, which merely require generic computer implementation, fail to transform [an] abstract idea into a patent-eligible invention.’).”

The ’002 patent

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

“Under step two, we conclude that the claims recite no ‘inventive concept’ to transform the abstract idea of remotely accessing user-specific information into a patent eligible application of that abstract idea. Rather, the claims merely recite generic, computer implementations of the abstract idea itself.”