computer aided method : CAFC Alert

CAFC provides guidance for patent eligibility of computer aided methods

| February 1, 2012

Dealertrack v. Huber

January 20, 2012

Panel:  Linn, Plager Dyk. Opinion by Linn.  Dissent by Plager.


The CAFC affirmed the district court’s grant of summary judgment of invalidity for patent ineligibility under § 101.  The CAFC stated that the claim at issue recited a “computer aided method” without reciting how the 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 claims are invalid as being directed to an abstract idea preemptive of a fundamental concept or idea that would foreclose innovation in this area.  Other issues were addressed in the opinion; however, this discussion only addresses the issue of patent eligibility under § 101.

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