Addressing whether patent claims were directed to abstract
ideas, the US Court of Appeals for the Federal Circuit found that a
number of claims directed to organizing and presenting information
in electronic spreadsheets were patent eligible while other claims
were ineligible. Data
Engine Techs. LLC v. Google LLC, Case No. 17-1135 (Fed.
Cir. Oct. 9, 2018) (Stoll, J). The Court followed the now-familiar
two-step Alice test for determining (1) whether the claims
were directed to a patent-ineligible concept and (2) if so, whether
the combination of elements transformed the nature of the claim
into a patent-eligible application of the concept.
Multiple claims from four patents were at issue in the appeal,
and the Federal Circuit discussed three representative claims. One
representative claim related to navigating through
three-dimensional electronic spreadsheets. A second representative
claim related to creating a tabbed spreadsheet where the tabs can
be named by the
