No Ticket To Ride For Transit-Limited Claims

The US Court of Appeals for the Federal Circuit affirmed a district court ruling that claims directed to the specific field of mass transit were directed to patent-ineligible subject matter under 35 USC § 101 because they failed both steps of the Alice inquiry. The Court found that the claims were directed to an abstract idea and otherwise lacked inventive concept. Smart Systems Innovations, LLC v. Chicago Transit Authority, Case No. 16-1233 (Fed. Cir., Oct. 18, 2017) (Wallach, J) (Linn, J, concurring in part and dissenting in part).

The representative claims in issue, taken from four related patents, were directed to either payment systems using a bankcard in connection with accessing mass transit, or data collection and storage systems regarding such payment systems. At the district court, the Chicago Transit Authority filed a motion for judgment on the pleadings, asserting that the claims were subject matter ineligible under 35 USC § 101. After the district