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ARTICLE · 26 OCTOBER 2017

Return To Sender: Mail Tracking With Barcodes And URLs Found Not Patent Eligible

Finnegan, Henderson, Farabow, Garrett & Dunner LLP
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In Secured Mail Solutions LLC v. Universal Wilde, Inc., No. 16-1728 (Fed. Cir. Oct. 16, 2017), the Federal Circuit affirmed the lower court's dismissal for failure to state a claim..

United StatesIntellectual Property
Finnegan, Henderson, Farabow, Garrett & Dunner, LLP
Finnegan, Henderson, Farabow, Garrett & Dunner, LLP
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In Secured Mail Solutions LLC v. Universal Wilde, Inc., No. 16-1728 (Fed. Cir. Oct. 16, 2017), the Federal Circuit affirmed the lower court's dismissal for failure to state a claim, finding that Secured Mail's patents were directed to the patent-ineligible abstract idea of communicating information about a mail object using markings. Secured Mail sued Universal Wilde, alleging infringement of seven patents directed to attaching identifiers, such as barcodes or URLs, to mail objects. The district court held that the patents were not directed to patent-eligible subject matter.

On appeal, the Federal Circuit affirmed, rejecting Secured Mail's argument that the district court characterized the claims at an unduly high level of abstraction and that the claims were directed to a "sender-generated unique identifier," which improved existing processes. The court held that Secured Mail's patents' claims were directed to the abstract idea of using a marking on the outside of

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