BSG TECH LLC v. BUYSEASONS, INC.
Federal Circuit Summary
Before Reyna, Wallach, and Hughes. Appeal from the District Court for the Eastern District of Texas.
Summary: When the only unconventional feature of the patent claim is what has already been determined to be an abstract idea, the patent claim is ineligible under § 101.
BSG Tech LLC (“BSG”) sued BuySeasons, Inc. (“BuySeasons”) for infringement of several patents related to systems and methods for indexing information stored in wide access databases. The patents relate to indexing software that organizes information about various items using classifications, parameters, and values. The patents taught a “self-evolving” aspect that enables users to “add new parameters for use in describing items.” On a motion to dismiss that was converted into a motion for summary judgment, the U.S. District Court for the Eastern District of Texas found that all of the asserted claims were invalid under 35 U.S.C. § 101. BuySeasons subsequently appealed, and the Federal Circuit affirmed.
Under step one of Alice, the Federal Circuit agreed with the district court that the asserted claims were directed to the abstract idea of considering historical usage information while inputting data. The Federal Circuit found that this was not a method “necessarily rooted in computer technology in order to overcome a problem specifically arising in the realm of” wide access databases. DDR Holdings, LLC v. Hotels.com, L.P., 773 F.3d 1245, 1257 (Fed. Cir. 2014). Further, the Federal Circuit found that the claims were not saved from abstraction merely because they require a specific database structure that is more specific than a generic computer. Also, the Federal Circuit stated that the claims did not recite any improvement to the way in which databases store or organize information.
Under step two of Alice, the Federal Circuit also agreed with the district court that the asserted claims lacked an inventive concept. BSG alleged that the “requirement that users are guided by summary comparison usage information or relative historical usage information” was an unconventional feature. However, the Federal Circuit found that this simply restates what was already determined to be an abstract idea.
This case is: BSG TECH LLC v. BUYSEASONS, INC.