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Move v. Real Estate Alliance

Representative Claim

1. A method using a computer for locating available real estate properties comprising the steps of:

  1. creating a database of the available real estate properties;
  2. displaying a map of a desired geographic area;
  3. selecting a first area having boundaries within the geographic area;
  4. zooming in on the first area of the displayed map to about the boundaries of the first area to display a higher level of detail than the displayed map;
  5. displaying the zoomed first area;
  6. selecting a second area having boundaries within the zoomed first area;
  7. displaying the second area and a plurality of points within the second area, each point representing the appropriate geographic location of an available real estate property; and
  8. identifying available real estate properties within the database which are located within the second area.

Posture:

Appeal from the United States District Court for the Central District of California in Nos. 2:07-cv-02185-GHKAJW, 2:08-cv-01657-GHK-AJW

Abstract Idea: Yes

The Federal Circuit agreed with the District Court that

“claim 1 [of the ‘989 patent] is aspirational in nature and devoid of any implementation details or technical description that would permit us to conclude that the claim as a whole is directed to something other than the abstract idea identified by the district court.”

While the Court was careful to explain that not “every claim involving the collection, organization, manipulation, or display of data is necessarily directed to an abstract idea,” it drew parallels with previous cases where it had made that precise determination, i.e. Electric Power Group, LLC v. Alstom S.A., 830 F.3d 1350 (Fed. Cir. 2016) and Intellectual Ventures I LLC v. Capital One Fin. Corp., 850 F.3d 1332 (Fed. Cir. 2017). The Court also distinguished the ‘989 patent from cases where the claims were directed to technical improvements, e.g., Enfish, LLC v. Microsoft Corp., 822 F.3d 1327 (Fed. Cir. 2016) and Visual Memory LLC v. NVIDIA Corp., 867 F.3d 1253 (Fed. Cir. 2017).

Something More: No

The Federal Circuit also agreed with the District Court’s Step Two determination that the ‘989 patent lacked an “inventive concept [either] in the individual claim limitations or their ordered combination” because Claim 1 calls only for “generic computer components and features.”