Patents Claiming Systems and Methods for Electronic Sale of Fixed-Income Assets Deemed Invalid for Failure to Claim Patentable Subject Matter

The court granted plaintiff's motion for summary judgment that defendant's patents related to the electronic sale of fixed-income assets were invalid for failing to claim patent-eligible subject matter. "The patents are directed at 'systems and methods that allow for the electronic sale of a component of a fixed income asset' . . . Defendant emphasizes that the method recites neither 'a mathematical formula' nor a 'fundamental economic practice,' and stresses the method's use of computer components. But a review of the substance of the claim demonstrates that, at its core, the claim is directed toward computer components that are used simply to facilitate the computation of various equations. As this Court previously stated, the use of the machine must be more than 'incidental use . . . to perform [a] mental process.'"

Federal Home Loan Mortgage Corporation v. Graff/Ross Holdings LLP, 1-10-cv-01948 (DCD September 27, 2012, Order) (Leon, J.).