The recent U.S. case of CLS Bank v. Alice addresses patent eligibility requirements for computer-implemented business and financial methods.
Alice is an Australian company that owns four United States patents; it asserts that CLS infringes these four patents. CLS is an “Edge Act Corporation,” organized under Section 25A of the Federal Reserve Act, as amended, 12 U.S.C. § 611, and authorized by statute to engage in international banking activities.
Summary provided by the U.S. law firm that represented the successful party: On March 9, 2011, the U.S. District Court for the District of Columbia dismissed all claims of patent infringement brought under four patents directed to computer-implemented methods, systems, and products for exchanging a financial obligation, because each of the patent claims was directed to an “abstract idea” and was invalid because it was directed to non-patentable subject matter. The decision is significant because, among other things, it addressed numerous questions left unanswered by the U.S. Supreme Court’s decision last year in Bilski v. Kappos, 130 S. Ct. 3218 (2010). This Client Alert reviews the decision and the significance the decision may have on the scope of the abstract idea exception that had not been addressed either by the Federal Circuit or by the Supreme Court in their respective Bilski decisions.