In CLS Bank International v. Alice Corp., No. 11-1301 (Fed. Cir. July 9, 2012), the Federal Circuit reversed the district court’s grant of SJ, finding that the system, method, and media claims of the
patents-in-suit are not directed to mere abstract ideas, but rather to practical applications of invention that are patent eligible under 35 U.S.C. § 101. The Court noted that where the addition of a machine imposes a meaningful limit on the scope of a claim and plays a significant part in permitting the claimed method to be performed, that machine limitation may render the claim patent eligible. The Court held that “when—after taking all of the claim recitations into consideration—it is not manifestly evident that a claim is directed to a patent ineligible abstract idea, that claim must not be deemed for that reason to be inadequate under § 101.” Slip op. at 20.
See this month’s edition of Last Month at the Federal Circuit for a full summary of this decision.