Job Candidate Evaluation Patent Invalid Under 35 U.S.C. § 101

The court granted defendant's motion to dismiss because the asserted claims of plaintiff’s job candidate evaluation patent encompassed unpatentable subject matter and found that the claims were directed toward an abstract idea. "The [patent-in-suit] has a very simple premise: anonymously surveying references and compiling the survey data before interviewing applicants will help companies only interview the best applicants. The [patent] is 'trying to achieve,' the abstract idea of reference checking job applicants. . . . In this case, the claims, alone and in combination, could all be completed by the human mind. A pen and paper version of the claimed method would not be particularly efficient, but it could be completed."

SkillSurvey, Inc. v. Checkster LLC, 2-15-cv-01766 (PAED March 31, 2016, Order) (Jones, J.)