Forecast Unfavorable for Inventory Software Patent

Ever since the Supreme Court's decision in Alice Corp. v. CLS Bank shifted the contours of patent-eligible subject matter, district courts have wielded the two-part test set forth in that decision to dispatch scores of business method patents as being directed to unpatentable abstract ideas.  In a recent example, the Massachusetts district court invalidated a patent relating to inventory forecasting software using the Alice test.

In November 2015, Plaintiff Smart Software sued defendant PlanningEdge, alleging that PlanningEdge's forecasting software infringed U.S. Patent No. 6,205,431 (the "'431 patent"), owned by Smart Software and directed to a system and method for forecasting intermittent demand to help manage inventory. Shortly thereafter, PlanningEdge filed a motion to dismiss arguing that the '431 patent claimed patent-ineligible subject matter under § 101 of the Patent Act.