Financial Product Price Quote Patent Invalid Under Alice

The court granted defendants' motions to dismiss plaintiff's infringement action for lack of patentable subject matter and found the abstract idea in plaintiff's financial product price quote patent was not limited by an inventive concept. "The [patent-in-suit] does precisely what . . . is fatal to many computer-based patents: 'recite the performance of some business practice known from the pre-Internet world along with the requirement to perform it on the Internet.' The generation of price quotes for financial products is undeniably a pre-Internet concept. . . . [Plaintiff's] contention that it is solely offering an 'improvement' to overcome a purely technical problem is belied by the broad, non-limited claim language. . . . The court's holding is bolstered by [plaintiff's] own repeated use of language concerning 'scalability.'. . . But this is the exact same role computers play in many cases involving abstract, non-patentable ideas."

The Money Suite Company v. 21st Century Insurance and Financial Services Inc., et al, 1-13-cv-00984 (DED January 27, 2015, Order) (Sleet, J.)