PTAB Issues First Final Written Decision in CBM Proceeding

On June 11, 2013, the Patent Trial and Appeal Board (PTAB) issued its first final written decision in a Post Grant Review proceeding under the Transitional Program for Covered Business Method Patents in case CBM2012-00001 (SAP America, Inc. et al. v. Versata Development Group, Inc.). The PTAB’s decision found all of the challenged claims of Versata’s U.S. Patent No. 6,553,350 unpatentable under 35 U.S.C. § 101.

In particular, the PTAB found that the ’350 patent claims recited abstract ideas that are not eligible for patenting. The ’350 patent claims systems and methods for pricing products using customer and product hierarchies, which the PTAB found to be abstract ideas without “enough significant meaningful limitations to transform these abstract ideas into patent-eligible applications.” The PTAB therefore issued an order cancelling all of the challenged claims as unpatentable. A copy of the PTAB’s decision can be found here.