Carfax, Inc. v. Red Mountain Technologies, LLC et al, 1-14-cv-01590 (VAED March 30, 2015, Order) (Lee, J.)
Friday, April 10, 2015
Vehicle Insurance Patents Invalid Under Alice
The court granted defendant's motion to dismiss because the two asserted patents were directed to the abstract ideas of underwriting an insurance policy and determining the insurability of a vehicle and accorded no inventive step that would make the abstract ideas patent eligible. "[The claims] state that the components and apparatus are for calculating insurability. However . . . the claims [do not] explain how the process transforms a particular article into a different state or thing and mere recitation of a generic computer cannot transform a patent-ineligible abstract idea into a patent-eligible invention. The Court finds that [the claims] do not pass the muster of machine-or-transformation test, therefore they do not transform the abstract idea of determining insurability of a vehicle to an inventive computer concept. . . . Because [an exemplary claim] is directed toward a business method of 'organizing human activity' for 'underwriting an insurance policy,' the Court finds that it is directed toward an abstract idea. . . . Even if the Court found that [the claim] was not directed towards an abstract method of organizing human activity, the Court finds that it is directed at a well-established, fundamental practice."