Financial Transaction Security Patent Invalid Under Alice

The court granted defendant's motion for summary judgment that plaintiff's financial transaction security patent was invalid for lack of patentable subject matter because the claims were not limited by an inventive concept. "[P]laintiff argues that the claims use 'specific computers' with bank processing software, making them 'special purpose computers.' . . . Plaintiff admits that the applicant did not invent the computer components or the banking software. For example, claim 30 utilizes a memory to store a limitation or restriction, a communication device to transmit, a receiver to receive, and a processing device to process information and generate a signal containing information. While plaintiff objects to the characterization of these components as generic, the addition of well known data processing software does not transform these components into a 'special purpose computer.'. . . While the computer components do allow the abstract idea to be performed more quickly, this does not impose a meaningful limit on the scope of the claim."

Joao Bock Transaction Systems LLC v. Jack Henry & Associates Inc., 1-12-cv-01138 (DED December 15, 2014, Order) (Robinson, J.)