ARTICLE · 12 MAY 2015

Conventional Use Of Computer Not Enough To Overcome Alice

McDermott Will & Emery

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The patent owner argued that the challenged claims "do not monopolize any abstract ideas" and "merely involve, but do not manifestly describe, the abstract idea of ‘providing financing.'"

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Westlake Services, LLC v. Credit Acceptance Corp.; Regions Financial Corporation, Advance America, Cash, et al. v. Retirement Capital Access Management Company LLC

In two separate decisions involving an § 101 analysis of subject-matter eligibility of business methods patents (CBMs), the U.S. Patent and Trademark Office's Patent Trial and Appeal Board (PTAB or Board) found that the challenged patents were directed to non-eligible subject matter in light of Alice. Westlake Services, LLC v. Credit Acceptance Corp., Case No. CBM2014-00008 (PTAB, Mar. 24, 2015) (Anderson, APJ); Regions Financial Corporation, Advance America, Cash, et al. v. Retirement Capital Access Management Company LLC, Case No. CBM2014-00012 (PTAB, Mar. 23, 2015) (Ward, APJ).

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