Alice Corp. v. CLS Bank Int'l

Summary

The Supreme Court held that Alice Corporation's patent claims concerning computerized intermediated settlement were directed to the patent-ineligible abstract idea of intermediated settlement under 35 U.S.C. § 101. The Court further held that implementing the abstract idea using generic computer components did not supply an inventive concept sufficient to make the claims patent eligible. The Court affirmed the Federal Circuit's judgment.

Holdings

1. The claims are directed to the patent-ineligible abstract idea of intermediated settlement—the use of a third party to mitigate settlement risk.
2. The method claims are not patent eligible because they merely instruct practitioners to implement the abstract idea of intermediated settlement on a generic computer.
3. The system and computer-readable-medium claims are also patent ineligible because they add nothing of substance to the underlying abstract idea.

Questions Presented

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

Disposition

affirmed