Judge Gregory M. Sleet recently granted a defendant’s motion for judgment on the pleadings of invalidity under § 101. Inventor Holdings, LLC v. Bed Bath & Beyond Inc., C.A. No. 14-448-GMS (D. Del. Aug. 21, 2015). The plaintiff’s patent claimed a “method and system for processing payments for remotely purchased goods,” which the defendant argued was invalid “because the claims at issue embody the abstract idea of paying for remote orders at local retailers.” Id. at 2-3. Judge Sleet agreed, explaining that “[t]he claims simply tell a practitioner that a remote merchant can direct a customer to pay for goods at a third-party, local merchant that has agreed to accept payments for the remotely-ordered goods and to tell the remote merchant when the customer has paid for the goods so that the remote merchant can then ship the goods—nothing more.” Id. at 8. The Court therefore found that the patent claimed an abstract idea – a “conventional business practice” – and lacked any inventive concept.