Patent Directed to the Production of an Insurance Claim Valuation Report Unpatentable Under 35 U.S.C. § 101

In a final written decision, the Board found claims of a patent directed to the production of an insurance claim valuation report unpatentable under 35 U.S.C. § 101. "Here, we observe that each challenged claim is directed to the fundamental concept of providing a vehicle valuation using information about the vehicle. Patent Owner contends that, unlike the claims in [Parker v. Flook, 437 U.S. 584 (1978)], the claims at issue in the instant proceeding are not drawn to an algorithm. When the claims are analyzed as a whole, as urged by Patent Owner, however, the claims recite nothing more than the collection of information to generate a valuation report for a damaged vehicle. Moreover, all the steps could be performed without the use of a computer. . . .The fact that the claims at issue are not per se drawn to an algorithm does not insulate them from being found an abstract idea."

Petition for Covered Business Method Patent Review by Mitchell International, Inc., CBM2014-00171 (PTAB February 19, 2016, Order) (Green, APJ)