Petition for Covered Business Method Patent Review by Life Technologies, CBM2015-00037 (PTAB June 28, 2016, Order) (Bonilla, APJ)
Thursday, June 30, 2016
Electronic Inventory Management Patent Unpatentable Under 35 U.S.C. § 101
In a final written decision, the Board found the challenged claims of a electronic inventory tracking patent to be unpatentable under 35 U.S.C. § 101 and that the claims were directed to the abstract idea of inventory management. "[T]he challenged claims are directed to the abstract idea of inventory management that takes advantage of certain data and information that is collected, stored, evaluated, and used, and provides access to information based on assigned permissions and roles. The recited databases, software, computer, and assigned permissions or roles perform their normal functions, as used in their ordinary capacity. We are not persuaded 'the plain focus' of the challenged claims here 'is on an improvement to computer functionality itself, not on economic or other tasks for which a computer is used in its ordinary capacity.' Thus, we determine that challenged claims 67 and 70– 76 are directed to an abstract idea, and the first step in the Alice/Mayo test is met for those claims."