The Board has once again applied the Mayo/Alice test for
patent eligibility, this time in the final written decision for United States
Postal Service v. Return Mail Inc., CBM2014-00116, finding all
six challenged claims unpatentable under 35 U.S.C.
§ 101. The patent bar as a whole, and
this blog in particular, have noted how deadly § 101
has become post-Alice.
The patent claims a method in which, after mail is returned as
undeliverable, a corrected address is electronically provided,
either to the sender or to a related mail service provider.
In its petition, the USPS asserted that communicating address
information whenever an incorrect address turns up is an abstract
idea, and simply communicating and encoding the data electronically
is insignificant post-solution activity, not "significantly
more" in the Mayo/Alice parlance. The patent owner,
Return Mail, emphasized the electronic transmission and
encoding/decoding to argue that the claimed method improved
