Claims Invalid Under § 101 Where Inventive Concept Itself Is Abstract

PersonalWeb Techs. LLC v. Google LLC, Nos. 2020-1543, 2020-1553, 2020-1554 (Fed. Cir. August 12, 2021)

The Federal Circuit affirmed the district court's decision granting judgment on the pleadings that the claims were directed to abstract ideas and thus invalid under 35 U.S.C. § 101. The claims related to "data-processing systems that assign each data item a substantially unique name that depends on the item's content—a content-based identifier." These identifiers are generated by a mathematical algorithm, and the identifier changes when the data item's content changes. The claims then recited "using such identifiers to perform various data-management functions."

At step one of the two-step Alice/Mayo framework, the Federal Circuit agreed that the claims were directed to abstract ideas. Each step in the claimed methods reflected a concept that the Federal Circuit "already described as abstract" and involved "mental processes that 'can be performed in the human