Patent for Storing and Retrieving Transaction Information Via Nonpredictable Barcode Not Invalid Under 35 U.S.C. § 101 ​

The court denied defendant's motion to dismiss on the ground that the asserted claims of plaintiff’s patent for storing and retrieving transaction information via a nonpredictable barcode encompassed unpatentable subject matter because there was a significant improvement to the computer functionality. "[Defendant] contends that the [patent-in-suit] is directed toward the abstract idea of retrieving transaction records. . . . [Defendant] takes an overly generalized view of the claim language that vitiates meaningful limitations. [Defendant's] recitation of the claims ignores (or at least evades) the elements of 'nonpredictable bar code' and 'transaction information associated with a nonpredictable bar code.' These elements place substantial limitations on the scope of the asserted claims. . . . [Defendant] dismisses the nonpredictable bar code limitation because it was 'known in the prior art.' But a claim does not fail [Alice Corp. Pty. Ltd. v. CLS Bank Int’l, 134 S. Ct. 2347 (2014)] scrutiny merely because it recites elements known in the prior art. . . . Here, the invention lies in the combined use of nonpredictable bar codes with transaction information. Far from conventional, this novel combination resulted in an improvement over the mid-1990s accounting software, which relied on manual entry of transaction information. Furthermore, the specification teaches that using nonpredictable bar codes to transmit transaction information over a network constitutes a 'significant improvement in that transaction data . . . can be accessed by an end user without concern by unauthorized parties.'”

Intellectual Ventures I LLC et al v. J Crew Group, Inc., 6-16-cv-00196 (TXED August 24, 2016, Order) (Gilstrap, USDJ)