Combination of Abstract Ideas Does Not Render Unpatentable Subject Matter Patent Eligible Under Alice

The court granted defendant's motion for judgment on the pleadings that plaintiff's payroll processing patent was invalid for lack of patentable subject matter and rejected plaintiff's argument that the patent satisfied the standard in Alice Corporation Pty. Ltd. v. CLS Bank International, 134 S. Ct. 2347 (2014) because it covered a 'plurality' of abstract ideas. "[E]ven viewing the claims in the light most favorable to [plaintiff], the [patent-in-suit] is directed to the unitary abstract idea of cataloging labor data. Even if that were not so, however, the Court is aware of no case holding that merely combining two or three abstract ideas brings a patent within the scope of § 101, and the available authority tends to suggest the contrary. . . . There may be some point when a combination of abstract ideas becomes concrete invention; if broken down finely enough, virtually any invention could perhaps be characterized as a combination of abstract concepts, laws of nature, and the like. Merely using routine organization of data to serve a handful of different purposes does not, however, rise to that level."

Shortridge v. Foundation Construction Payroll Service, LLC d/b/a Payroll4Construction.com et al, 3-14-cv-04850 (CAND April 14, 2015, Order) (Spero, M.J.)