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Dealertrack v. Huber (674 F.3d 1315, 2012 Jan 20)

Decision Parameters

Decisions It Cites

    Gottschalk v. Benson [409 U.S. 63, 1972]
    Diamond v. Chakrabarty [447 U.S. 303, 1980]
    Diamond v. Diehr [450 U.S. 175, 1981]
    Bilski v. Kappos [561 U.S. 593, 2010]
    Research Corp v. Microsoft [627 F.3d 859, 2010]
    Ultramercial v. Hulu I [657 F.3d 1323, 2011]

Decisions That Cite It

Rules & Quotes

[ABSTRACT, DESCRIPTION] {1} Although the district court construed “computer aided” as a limitation, the '427 Patent “does not specify how the computer hardware and database are specially programmed to perform the steps claimed in the patent.” See Invalidity at 1156. The claims are silent as to how a computer aids the method, the extent to which a computer aids the method, or the significance of a computer to the performance of the method. The undefined phrase “computer aided” is no less abstract than the idea of a clearinghouse itself. Because the computer here “can be programmed to perform very different tasks in very different ways,” Aristocrat, 521 F.3d at 1333, it does not “play a significant part in permitting the claimed method to be performed.” Cybersource, slip op. at 19 (citing SiRF Tech., 601 F.3d at 1333). Simply adding a “computer aided” limitation to a claim covering an abstract concept, without more, is insufficient to render the claim patent eligible. The claims here do not require a specific application, nor are they tied to a particular machine. ... Similarly, here, the claims cover a clearinghouse process using any existing or future-devised machinery. ... The fact that certain algorithms are disclosed in the specification does not change the outcome. In considering patent eligibility under Section 101, one must focus on the claims. This is because a claim may "preempt" only that which the claims encompass, not what is disclosed but left unclaimed. Here, the claims of the '427 Patent were construed not to be limited to any particular algorithm.

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