By Memorandum Opinion entered by The Honorable Gregory M. Sleet in The Money Suite v. 21st Century Insurance and Financial Services, Inc., et al., Civil Action No. 13-984-GMS (D.Del., January 27, 2015) (consolidated), the Court granted defendants’ joint motion to dismiss all of the actions filed by plaintiff against them alleging infringement of U.S. Patent No. 6,684,189 (“the ‘189 Patent”) after finding that the ‘189 patent was invalid under 35 U.S.C. § 101 because it claimed a patent-ineligible subject matter. In so ruling, the Court found that the ‘189 Patent and all of its 887 claims are invalid because they claim an abstract idea – providing price quotes for various financial products and services – without meaningfully narrowing the scope of coverage. See id. at 5.
A copy of the Memorandum Opinion is attached.
The takeaway from this case is that, when evaluating a patent that potentially claims an abstract idea, isolate the independent claim(s) and carefully evaluate whether there are sufficient inventive elements such that the claimed invention is significantly more than a patent on an ineligible concept using the two-step framework set forth by the U.S. Supreme Court in Alice Corp. Pty. Ltd. v. CLS Bank International, 134 S.Ct. 2347, 2355 (2014).