Advantage Over Prior Methods Inadequate To Confer Patent Eligibility Without Technological Improvement

In a short, two-page opinion, the U.S. Court of Appeals for the Federal Circuit affirmed the U.S. District Court for the Southern District of Indiana's ruling that a method of using peer-to-peer networking to verify employment history in the truck driving industry was directed to patent-ineligible subject matter under Section 101.

Tenstreet argued that the asserted patent claims were eligible because they provided three advantages over conventional processes for employment verification: 1) a single channel for routing transmissions, 2) the ability for job applicants to monitor the verification process and 3) database storage of employment history.

The Federal Circuit disagreed that these three advantages constituted eligible subject matter, stating that the "test for patent-eligible subject matter is not whether the claims are advantageous over the previous method." Even if the patent "provides advantages over manual collection of data, the patent claims no