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TDE Petroleum Data Solutions v. AKM Enterprise

Representative Claim

  1. An automated method for determining the state of a well operation, comprising:

a. storing a plurality of states for a well operation; receiving mechanical and hydraulic data reported for the well operation from a plurality of systems; and
b. determining that at least some of the data is valid by comparing the at least some of the data to at least one limit, the at least one limit indicative of a threshold at which the at least some of the data do not accurately represent the mechanical or hydraulic condition purportedly represented by the at least some of the data; and
c. when at least some of the data are valid, based on the mechanical and hydraulic data, automatically selecting one of the states as the state of the well operation.

Posture:

Appeal from the United States District Court for the Southern District of Texas in No. 4:15–cv–01821, Judge Gray H. Miller.

Abstract Idea: Yes

The Federal Circuit found that the claimed steps recited “operations performed by any general-purpose computer.”  It reiterated prior holdings that claims generally reciting “collecting information, analyzing it, and displaying certain results of the collection and analysis” are “a familiar class of claims ‘directed to’ a patent-ineligible concept.”  The Federal Circuit stated that the representative claim recited “all but the ‘displaying’ step,” and it was therefore clear “that claim 1 is the sort of data gathering and processing claim that is directed to an abstract idea under step one of the Alice analysis.”

Something More: No

The patent owner did not and could not “argue that storing state values, receiving sensor data, validating sensor data, or determining a state based on sensor data is individually inventive.”  Additionally, the Federal Circuit found the patent owner’s arguments “that some inventive concept arise[] from the ordered combination of these steps” was “unpersuasive given that they [were] the most ordinary of steps in data analysis and are recited in the ordinary order.”  While the specification arguably provided specific embodiments for the step of “automatically selecting one of the states as the state of the well operation,” the representative claim recited none of those details. Instead, the representative claim simply recited “generic computer functions that amount to nothing more than the goal of determining the state of an oil well operation.”  Relying on precedent, the Federal Circuit held “the claims of the ‘812 patent recite the what of the invention, but none of the how that is necessary to turn the abstract idea into a patent-eligible application.”