Alice Corp. v. CLS Bank Int'l

Summary

The Supreme Court held that the asserted claims covering a computer-implemented scheme for mitigating settlement risk through intermediated settlement are directed to the abstract idea of intermediated settlement. The Court concluded that implementing the idea using generic computer components and conventional computer functions did not supply an inventive concept sufficient for patent eligibility under 35 U.S.C. § 101. The Court affirmed the Federal Circuit's judgment that the method, system, and computer-readable-medium claims were patent ineligible.

Holdings

1. The asserted claims are directed to the abstract idea of intermediated settlement, meaning the use of a third-party intermediary to mitigate settlement risk.
2. Merely requiring generic computer implementation of an abstract idea does not transform the idea into a patent-eligible invention.
3. The system claims are patent ineligible because the recited data-processing system, communications controller, and data-storage unit are generic computer components configured to implement the same abstract idea as the method claims.
4. The computer-readable-medium claims are patent ineligible for substantially the same reasons as the method claims.

Questions Presented

1. Whether the asserted method, system, and computer-readable-medium claims are patent eligible under 35 U.S.C. § 101.
2. Whether the claims are directed to the abstract idea of intermediated settlement.
3. Whether generic computer implementation supplies an inventive concept sufficient to transform the abstract idea into a patent-eligible invention.

Disposition

affirmed