Transaction Entry System Patent Held Invalid for Failure to Claim Patentable Subject Matter

The court granted defendants' early summary judgment motion and found that plaintiff's transaction entry system patent was invalid for failing to claim patentable subject matter. "[T]he court finds that the abstract nature of plaintiff's patent is plainly apparent. The patent, broken down into its component parts, recites steps by which data is obtained, sorted and stored. These steps represent nothing more than a disembodied concept of data sorting and storage and, therefore, the court finds the abstract nature of this patented process to be manifestly apparent. . . . [T]he use of a telephone to capture data does not make the abstract concepts of sorting and storing data somehow patent-eligible. To the extent that a machine is also involved in the sorting or organizing step (step two), that . . . machine is just a general purpose computing device being asked to do some unspecified sorting function. Claiming a generic 'computer-aided' sorting process is insufficient under the machine prong of the [machine-or-transformation test]. Essentially plaintiff has claimed nothing more than the idea of sorting via machine."

CyberFone Systems LLC v. Cellco Partnership, et. al., 1-11-cv-00827 (DED August 16, 2012, Order) (Robinson, J.).