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ARTICLE · 11 FEBRUARY 2015

Claims Directed To Document Data Extraction Technology Not Patent Eligible Under § 101

Finnegan, Henderson, Farabow, Garrett & Dunner LLP
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In Content Extraction & Transmission LLC v. Wells Fargo Bank, the Federal Circuit affirmed the district court’s grant of a motion to dismiss under Fed. R. Civ. P. 12(b)(6), which found the asserted claims invalid...

United StatesIntellectual Property
Aaron Gleaton
Aaron Gleaton
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In Content Extraction & Transmission LLC v. Wells Fargo Bank, National Ass'n, Nos. 13-1588, -1589, 14-1112, -1687 (Fed. Cir. Dec. 23, 2014), the Federal Circuit affirmed the district court's grant of a motion to dismiss under Fed. R. Civ. P. 12(b)(6), which found the asserted claims invalid as patent ineligible under 35 U.S.C. § 101.

Content Extraction and Transmission LLC ("CET") owns U.S. Patent Nos. 5,258,855 ("the '855 patent"); 5,369,508 ("the '508 patent"); 5,625,465 ("the '465 patent"); and 5,768,416 ("the '416 patent") (collectively "the asserted patents"). The claims generally claim methods of extracting data from hard copy documents using scanning technology, recognizing specific information from the extracted data, and storing the data in memory.

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