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Judge Sleet finds patent invalid under 101, grants Rule 12 motion

In The Money Suite Company v. 21st Century Insurance and Financial Services, Inc., et al., C.A. No. 13-984-GMS (D. Del. Jan. 27, 2015) and a series of related actions (Nos. 13-986, 13-1747, and 13-1748-GMS), Judge Gregory M. Sleet granted defendants’ joint motion to dismiss (or for judgment on the pleadings), on the basis that the patent-in-suit was invalid as an abstract idea under Section 101.  The patent is directed to “a computerized method for generating price quotes for financial products.”  Id. at 2.

Citing Alice Corp., the Court concluded that the patent was indeed directed to an abstract idea, noting that the “concept is not dissimilar from those discussed by recent [Section] 101 court cases,” including Alice CorpId. at 5.  Furthermore, the patent’s “outlined sequence of steps [e.g., “the use of front-end network gateways to allow users to interface with remote servers in order to generate a price quote for financial products,” id. at 7] is neither inventive nor sufficiently narrow to alleviate preemption concerns.  The use of front-end network gateways . . . is not new[.]”  Id.  Further, “[l]eaving open the possibility of practicing the idea of price quoting financial products manually does not save the [patent-in-suit, as plaintiff contended].  This was the very concern underlying the court’s rationale in Alice: monopolizing computerized implementations while allowing the public to practice the idea ‘by hand’ does not comport with [Section] 101.”  Id. at 9.  The Court also distinguished the patent-in-suit from the patent upheld as valid in DDR Holdings, LLC v., 773 F.3d 1245 (Fed. Cir. 2014), explaining that the generation of price quotes for financial products was “undeniably a pre-Internet concept,” and thus the asserted claims did “precisely what DDR Holdings explains is fatal to many computer-based patents.”  Id. at 10.

As a result, the Court granted the defendants’ joint motion to dismiss based on Section 101 invalidity.  Id. at 11.

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