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Supreme Court rules on software patent case Alice Corp v. CLS Bank [pdf]

by sthu11182 on 6/19/14, 2:16 PM with 110 comments

  • by grellas on 6/19/14, 4:04 PM

    One of the horrid things about law is how it can be dissembled by those whose job is to practice it. This drives people crazy. They know something is real. Yet, especially if they are caught in its hooks, they watch how law can be applied such that results are absurdly divorced from the reality they know. Our advocacy process has many fine elements and yet this is one of its tragic by-products: having the best and the brightest in the field become instruments in trying to obtain cynically-motivated decisions that further some narrow (usually economic) interest at the expense of truth and justice.

    That has been happening for a long time now in the patent field as armies of very bright lawyers have found clever ways to concoct patents out of what really should be unpatentable ideas through the art of clever drafting.

    Well, this decision gives top-down guidance to judges to cut through such dissimulation in the area of patents and to look at the reality by asking, in effect, "is this really inventive or is it simply a product of the draftsman's craft parading as being somehow inventive." That is the right question to ask in such cases and it should go a long way towards reining in some of the more absurd abuses of recent times.

    The case in nonetheless only an incremental step building on solid precedent (as well-assessed by rayiner) and not a radical shift by the Court.

    Many had hoped, for example, that this case could be used as a means of delivering a death-blow to all software patents on the grounds that they could all be labeled nothing more than basic mathematical algorithms that happen to apply to a computer. Yet, in its decision, the Court not only did not address this sort of argument but it also carefully emphasized the idea that it was to "tread carefully" in how it might choose to exclude even fundamental "building blocks of human ingenuity" (i.e., laws of nature, natural phenomena, abstract ideas) from patent eligibility "lest this exclusionary principle . . . swallow up all of patent law." To me, this signifies that the cautious approach signaled in Bilski - that is, that of gradually cutting back on the excesses spawned in the past two decades in the area of patent-eligible subject matter - will continue. So don't hold your breath awaiting any court-driven abolition of software patents generally. That will have to await a legislative solution, if it is to come about at all.

  • by rayiner on 6/19/14, 2:59 PM

    This is a very good opinion, tightly argued based on the precedent. And frankly, unsurprising given the relevant precedent (Diehr, Benson, Mayo).

    The opinion has three parts:

    1) The Court identifies the abstract idea contained in the patent as the general concept of intermediated settlement. (Slip. Op. at 9) The key takeaway here is the discussion about whether an "abstract idea" has to be on the level of a "law of nature" in order to be excluded. The Court says that an abstract idea need not reduce to some fundamental truth that has always existed. It is sufficient for it to be a "fundamental economic practice" or "longstanding commercial practice," like the concept of "risk hedging" in Bilski. (Slip. Op. at 10)

    2) The Court looks to see if the patent adds anything more to the abstract idea, and concludes that all it does is describe how to implement the idea in a general computer, in the generic and conventional way. (Slip. Op. at 12, 15) The Court analogizes to Mayo, in which it decided that the claimed method amounted to no more than instructing doctors as to how to use a well-known process for measuring metabolite levels to diagnose their patients. (Slip. Op. at 11) The Court states that the claimed method simply describes how to instruct a computer to perform the abstract idea of intermediating settlement. The Court makes a point of noting that the computer implementation described here is "wholly generic" and that "[i]n short, each step does no more than require a generic computer to perform generic computer functions." (Slip. Op. at 13, 15)

    3) The Court concludes that the "system" claims are no different in substance from the method claims: "But what petitioner characterizes as specific hardware—a 'data processing system' with a 'communications controller' and 'data storage unit,' for example, see App. 954, 958, 1257—is purely functional and generic. Nearly every computer will include a 'communications controller' and 'data storage unit' capable of performing the basic calculation, storage, and transmission functions required by the method claims." (Slip. Op. at 16)

  • by jackgavigan on 6/19/14, 4:08 PM

    This is fantastic news. Those patents were ridiculous.

    Part of my day job is figuring out how to go about automating or "electronifying" processes relating to financial trading and risk management. In other words, I look at things that people currently do manually (or decide in their heads) and I figure out how it can be codified into language or an algorithm that a developer can turn into code.

    Patents like this (and plenty of similar patents that have been granted[1]) effectively try to claim ownership over the concept of automating what is usually (but not always) a pre-existing business process, using a computer. That's not invention. It's problem-solving. And it's not like the person filing the patent is even solving the problem - they're just patenting the concept of a solution to that problem.

    In effect, they're trying to patent my work output. It's like someone filed a patent ten years ago on "Methods and apparatus relating to the matching of people seeking temporary accomodation and householders who are willing to rent out their spare rooms", without ever actually having built implemented it, then popped up when Airbnb came along, saying "Hey, we have a patent on that! Pay up!"

    Good fucking riddance.

    [1] For examples, see http://www.faqs.org/patents/assignee/goldman-sachs-co/

  • by spacemanmatt on 6/19/14, 2:39 PM

    Today I mourn the end of Groklaw, where I would have gone to get the very finest in public discourse and debate about the ruling.
  • by notacoward on 6/19/14, 2:48 PM

    I think the key sentence is this.

    "claims, which merely require generic computer implementation, fail to transform that abstract idea into a patent-eligible invention"

    In other words, start with an idea that's not patentable because it's abstract. Merely specifying its implementation on a computer doesn't make the original idea more concrete or more patentable. Therefore the claim on the idea is invalid, therefore other claims based on that one are too. So what's left?

    If the application to a computer is itself both novel enough and concrete enough, then that might still be considered patentable. Is that possible? Isn't the application to a generic computer still basically an abstract idea? Must it be an application to a specific type of computer to qualify? I think questions of this sort are going to be the new battleground. The war continues, but the front has moved in what seems to be a good direction.

    Disclaimers: (1) IANAL, (2) I have a bunch of patents both granted and pending through my employer, so this decision might actually hurt me financially.

  • by revscat on 6/19/14, 2:45 PM

    From p. 15 of the decision:

    "The method claims do not, for example, purport to improve the functioning of the computer itself. See ibid. ('There is no specific or limiting recitation of... improved computer technology...'); Brief for United States as Amicus Curiae 28–30. Nor do they effect an improvement in any other technology or technical field. See, e.g., Diehr, 450 U. S., at 177–178. Instead, the claims at issue amount to 'nothing significantly more' than an instruction to apply the abstract idea of intermediated settlement using some unspecified, generic computer."

    I don't see this decision as being too far removed from previous decisions. Regardless, this is a step in the right direction, and is a(nother) blow against the patentability of abstract ideas, and a blow against the patent trolls.

    Separately, no decision on ABC vs. Aereo issued today. Aereo lives to see another day, then. Good.

  • by mbell on 6/19/14, 3:08 PM

    I think the section throwing out the BS 'computer system assembly' bit may have the largest impact. I've read a number of patents that use that as their only real mechanism to be granted (see page 16 section C).
  • by sanxiyn on 6/19/14, 3:03 PM

    Favorite quote:

    "This Court has long warned against interpreting 101 in ways that make patent eligibility depend simply on the draftman's art."

  • by cbr on 6/19/14, 2:39 PM

    "Held: Because the claims are drawn to a patent-ineligible abstract idea, they are not patent eligible"
  • by ajb on 6/19/14, 5:15 PM

    Is Gene Quinn pissed at this: http://www.ipwatchdog.com/2014/06/19/scotus-rules-alice-soft...

    "In what can only be described as an intellectually bankrupt opinion..."

    Wow.

    He thinks it will invalidate lots of software patents - not by invalidating software patents per se, but the way they have been written to date. I'm not qualified to give an opinion, but I would be interested to know if that is a mainstream view.

  • by helper on 6/19/14, 2:38 PM

    The Court has begun to limit the scope of software patents, but has not eliminated them. This ruling is a step in the right direction and the unanimity of the Court should be taken as a positive sign for future cases.
  • by higherpurpose on 6/19/14, 3:37 PM

    Some thoughts on the ruling:

    http://www.vox.com/2014/6/19/5824130/7-thoughts-on-the-supre...

    Shame they didn't abolish the business method patents at the very least, if not all software patents.

  • by not_that_noob on 6/19/14, 5:03 PM

    Great decision. Once in a while they do get it right :)

    The hard part was balancing genuine innovation (from small inventors, pharma, etc.) vs. squashing trolls. This goes a long way toward whacking trolls while leaving in place what the patent system was meant for - the fostering of innovation for the benefit of society. Well played.

  • by sanxiyn on 6/19/14, 2:50 PM

    This basically seems to be a verbatim repeat of Bilski v. Kappos.
  • by wes-exp on 6/19/14, 2:53 PM

  • by PolemicThoughts on 6/19/14, 2:47 PM

    “Simply appending conventional steps, specified at a high level of generality,” to a method already “well known in the art” is not “enough” to supply the “ ‘inventive concept’ ” needed to make this transformation [into a patent-eligible invention].

    How does this differ from/alter existing law? Is this ruling just a clarification?

  • by eqnoob123 on 6/19/14, 7:13 PM

    When I saw the headline I wished it was Alice Corp v. Bob Bank
  • by sthu11182 on 6/19/14, 2:25 PM

    A little more clarity on abstract ideas, but not much more
  • by zenciadam on 6/20/14, 1:39 AM

    rip amazon one click patent.
  • by spacemanmatt on 6/19/14, 3:52 PM

    Let the motions for summary judgement commence!