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Secured Mail Solutions LLC v. Universal Wilde, Inc.

Representative Claim

Claim 1 of the ’268 patent:

  1. A method of verifying mail identification data, comprising:

affixing mail identification data to at least one mail object, said mail identification data comprising a single set of encoded data that includes at least a unique identifier, sender data, recipient data and shipping method data, wherein said unique identifier consists of a numeric value assigned by a sender of said at least one mail object;

storing at least a verifying portion of said mail identification data;

receiving by a computer at least an authenticating portion of said mail identification data from at least one reception device via a network, wherein said authenticating portion of said mail identification data comprises at least said sender data and said shipping method data; and

providing by said computer mail verification data via said network when said authenticating portion of said mail identification data corresponds with said verifying portion of said mail identification data.

Posture:

Appeal from the United States District Court for the Central District of California’s grant of a motion to dismiss on grounds that the claims of seven asserted patents are directed to subject matter ineligible for patenting under 35 U.S.C. § 101.

Abstract Idea: Yes

The claims of the three sets of patents are not limited by rules or steps that establish how the focus of the methods is achieved. Instead, the claims embrace the abstract idea of using a marking affixed to the outside of a mail object to communicate information about the mail object, i.e., the sender, recipient, and contents of the mail object. Because the claims are directed to an abstract idea, we turn to the second step of the Alice inquiry.’

Something More: No

Secured Mail analogizes to DDR Holdings, LLC v. Hotels.com, L.P., which held claims that “specify how interactions with the Internet are manipulated to yield a desired result” and recite “a specific way to automate the creation of a composite web page by an ‘outsource provider’ that incorporates elements from multiple sources in order to solve a problem faced by websites on the Internet” are patent-eligible under section 101. 773 F.3d 1245, 1258–59 (Fed. Cir. 2014). The claims in Secured Mail’s patents are non-specific and lack technical detail. Rather than citing a specific way to solve a specific problem as in DDR, the asserted claims cite well known and conventional ways to allow generic communication between a sender and recipient using generic computer technology.

We see no inventive concept that transforms the nature of the claims into a patent-eligible application of the abstract idea.