Data Engine Technologies LLC V. Google LLC
- Oct 9 2018 |
- Category: CAFC Updates
Data Engine Technologies (“DET”) filed suit against Google and appeals the district court’s entry of judgment on the pleadings holding that the asserted claims of DET’s U.S. Patent Nos. 5,590,259; 5,784,545; 6,282,551; and 5,303,146 are ineligible under 35 U.S.C. § 101. The district court held that the asserted claims are directed to abstract ideas and fail to provide an inventive concept. The CAFC concludes that, with the exception of claim 1 of the ’551 patent, the asserted claims of the ’259, ’545, and ’551 patents (“Tab Patents”) which relate to systems and methods for making complex electronic spreadsheets more accessible by providing familiar, user-friendly interface objects, are directed to patent-eligible subject matter. These claims are not abstract, but rather are directed to a specific improved method for navigating through complex three-dimensional electronic spreadsheets. The CAFC agrees, however, that the asserted claims of the ’146 patent, reciting methods for tracking changes to data in spreadsheets, are directed to the abstract idea of collecting, recognizing, and storing changed information and finds nothing in these claims that provides an inventive concept sufficient to render the claims patent eligible. Accordingly, the CAFC affirms-in-part, reverses-in-part, and remands.