IN RE SARADA MOHAPATRA, FEDERAL CIRCUIT 2021 (SOFTWARE PATENTS)
Enabling a credit card user to change the security code on the card by using a web application, to counter credit card fraud, is too abstract to be patent-eligible.
Mr. Mohapatra’s patent application is directed to a method for countering credit card fraud by enabling a cardholder to change the card’s security code at any time by using a card account management facility accessible over the Internet. The claimed method provides that the new security code will be different from the code printed on the card and different from the last recorded code.
Claim 18 of the application, which is representative, recites the following:
18. A method for countering credit card fraud arising from compromised credit card information
by utilizing cardholder changeable card security code (CSC; also known as card verification…
Multilevel security claims were patent eligible because they were directed to solving a technical problem specific to computer network security. The district court correctly rejected Adobe’s ineligibility challenge.
NetScout Systems appealed from a judgment of the U.S. District Court for the Eastern District of Texas which held that NetScout willfully infringed various claims of U.S. Patent No. 6,665,725; 6,839,751; and 6,954,789 and held that the claims were valid under 35 U.S.C. §101.
Electronic Communication Technologies, LLC sued ShoppersChoice.com, LLC (“ShoppersChoice”), alleging that ShoppersChoice infringed claim 11 of U.S. Patent No. 9,373,261. The district court granted ShoppersChoice’s motion for judgment on the pleadings that claim 11 was invalid under 35 U.S.C. § 101.
This case involves U.S. Patent No. 7,149,510 relating to securing mobile phones against improper access by apps.
Customedia appealed a decision by the U.S. Patent and Trademark Office holding claims of U.S. Patent No. 8,719,090 and 9,053,494 ineligible under 35 U.S.C. § 101.