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

Data Engine Technologies LLC v. Google LLC

Claims to Tabbed Spreadsheet Interface Held Patent-Eligible

Data Engine Technologies LLC v. Google LLC906 F.3d 999 (Fed. Cir. Oct. 9, 2018) (Reyna, Bryson, STOLL) (D. Del.: Stark) (3 of 5 stars)

Fed Cir part-affirms, part-reverses judgment on the pleadings of § 101 invalidity as to asserted claims from four patents. The opinion addresses DET’s patents in two groups. The first “Tab Patents” relate to techniques for making complex, 3-D spreadsheets more navigable via the use of familiar, user-friendly interface objects like notebook tabs. The remaining patent related to techniques for tracking changes in electronic spreadsheets.

The Tab Patents: The district court erred; all but one of the asserted Tab Patent claims are patent-eligible. Applying Alice/Mayo step one, the opinion describes how a representative claim was not directed to an abstract idea, but to “a specific method for navigating through three-dimensional electronic spreadsheets.” 906 F.3d at 1007–08. It describes how the Tab Patents solved a known technological problem, in a particular way, and required a specific interface and implementation to do so. As in Core Wireless, 880 F.3d 1356 (Fed. Cir. 2018), the claims “differ[ed] from prior art navigation methods” and recited a “specific and particular manner of navigating a three-dimensional spreadsheet that improves the efficient functioning of computers.” Id. at 1009. The opinion rejects Google’s citation of cases holding that “methods of organizing and presenting information are abstract.” Id. at 1010. The opinion distinguishes Affinity Labs, 838 F.3d 1253 (Fed. Cir. 2013), as involving claims “entirely functional in nature,” and Intellectual Ventures I v. Capital One, 850 F.3d 1332 (Fed. Cir. 2017), and Intellectual Ventures I v. Erie Indemnity, 850 F.3d 1315 (Fed. Cir. 2017), as involving abstract indexing ideas that “did not recite any specific structure or improvement of computer functionality sufficient to render the claims not abstract.” 906 F.3d at 1010. That human beings have long used tabs to organize inventions is not contrary; such considerations may come up in the anticipation or obviousness inquiries. For the § 101 analysis, the opinion emphasizes the “functional improvement achieved by the specifically recited notebook tabs in the claimed methods.” Id. at 1011.

One Tab Patents claim was patent-ineligible however. Unlike the other claims, it did not recite the specific tab implementation of a notebook tab interface, and “cover[ed] any means for identifying electronic spreadsheet pages.” Id. at 1012. This was directed to an abstract idea at Alice/Mayo step one, and lacked any inventive concept at Alice/Mayo step two.

The Tracking Changes Patent: The district court did not err in finding the asserted claims patent-ineligible. “The concept of manually tracking modifications across multiple sheets is an abstract idea. The mere automation of this process does not negate its abstraction.” Id. at 1013. As in Context Extraction, 776 F.3d 1343 (Fed. Cir. 2014), these claims were “directed to the abstract idea of collecting, recognizing, and storing the recognized data in memory.” Id. The claims also lacked an inventive concept at Alice/Mayo step two.

KEYWORDS: SUBJECT-MATTER ELIGIBILITY; SECTION 101; JUDGMENT ON THE PLEADINGS