In a final written decision of a covered business method (CBM)
patent review, the Patent Trial and Appeal Board (PTAB or Board)
found the challenged claims unpatentable on multiple grounds and
clarified that, for the purpose of determining whether claims are
ineligible as abstract ideas under Alice, the absence of
complete preemption does not necessarily demonstrate patent
eligibility. Care N' Care Insurance Co. and TriZetto Corp.
v. Integrated Claims Systems, LLC, Case No. CBM2015-00062
(PTAB, July 28, 2016) (Jung, APJ).
Care N' Care filed a CBM petition against a patent owned by
Integrated Claims. The challenged patent was directed to "an
attachment integrated claims (AIC) system for preparing and
processing forms with integrated attachments," which were
described as being "digital insurance claims including Prior
Approval Claim (PAC) Applications containing both a text form and
an integrated digitized attachment." The CBM petition included
grounds of invalidity
