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Secured Mail Solutions LLC v. Universal Wilde, Inc.

Postal “Unique Identifier” Patents Held Patent-Ineligible

Secured Mail Solutions LLC v. Universal Wilde, Inc., 2017 U.S. App. LEXIS 20105 (Fed. Cir. Oct. 16, 2017) (Prost, Clevenger, REYNA) (C.D. Cal.: Carter) (3 of 5 stars)

Fed Cir affirms determination of subject matter ineligibility under § 101. The case involves multiple patents, and the opinion groups them into three categories and gives each category a brief discussion at each step of the Alice inquiry. At Alice step one, the opinion reasons that all three categories claim abstract ideas—first, the idea of using a “unique identifier” to identify the senders of mail; second, the idea of using a QR code for a similar purpose; and third, the idea of using a personalized URL as an identifier. The opinion rejects Secured Mail’s argument, under Enfish, 822 F.3d 1327 (Fed. Cir. 2016), that such analysis described the claims at too high a level of generality. At Alice step two, none of the categorized patents included an inventive concept sufficient to confer patent-eligibility. The opinion rejects Secured Mail’s citation to DDR Holdings, 773 F.3d 1245 (Fed. Cir. 2014), because the claims do no more than “cite well known and conventional ways to allow generic communication between a sender and a recipient using generic computer technology.” Op. at 12.

There was no error in the district court dismissing the case at the Rule 12(b)(6) stage. And the opinion rejects Secured Mail’s argument that the district court misplaced the burden of proof.

KEYWORDS: PATENT ELIGIBLE SUBJECT MATTER (NO)