Data Security Patent “Incidental or Complementary” to Financial Activity Subject to CBM Review

The Board granted institution of covered business method review of a data security patent and rejected the patent owner's argument that the challenged patent was not directed to a financial product or service. "Patent Owner [argues] that the Petition does not cite to 'any single word in any single claim' that is directed to a financial product of service; none of the prior art cited by Petitioner is directed to a financial product or service; and Petitioner does not cite any examples of actual financial products that employ the method of the claims. . . . [A]t least one claim claims a method for performing data processing or other operations that are at least incidental or complementary to the practice, administration, or management of a financial product or service. . . .The Specification discloses that protection attributes are used to protect against unauthorized access of a data portion in a database and that banking is a field where protection against unauthorized access to databases that are used for administering and storing sensitive information is desired."

Petition for Covered Business Method Patent Review by Informatica Corporation, CBM2015-00021 (PTAB June 1, 2015, Order) (Turner, APJ)