Defendant's motion for summary judgment of invalidity of plaintiffs' insurance claim processing patents was granted under Bilski v. Kappos, 130 S. Ct. 3218 (2010). "[Defendant] contends that the claims of the [patents-in-suit] contain abstract ideas and fail the machine or transformation test. . . . because their claims require only aspects of a general purpose computer. Moreover, [defendant] contends that the transfer of data regarding insurance cases from one electronic file to another does not transform physical objects to another state or thing. According to [defendant], all of the claims reflect field of use restrictions or insignificant post-solution activity and, therefore, constitute unpatentable abstract ideas under § 101. . . . This court previously determined that the [patents-in-suit] fail to satisfy the machine or transformation test. . . . Using the court's previous machine or transformation determination as an 'important clue' in the analysis, the court must now determine whether the claims as a whole convey an unpatentable, abstract idea. . . . [T]he [patents-in-suit] are directed to abstract and, therefore, unpatentable, methods and systems for generating file notes and tasks to be performed for insurance claims. The patents are directed to concepts for organizing data rather than to specific devices or systems, and limiting the claims to the insurance industry does not specify the claims sufficiently to allow for their survival."
Accenture Global Services GmbH, et. al. v. Guidewire Software Inc., 1-07-cv-00826 (DED May 31, 2011, Order) (Robinson, J.)
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