Knobbe/Martens: Intellectual Property Law

Federal Circuit Affirms Patent-Ineligibility of Claims Directed to Displaying Financial Information on a Known Device

By Adam Powell and Douglas B. Wentzel May 1, 2019

TRADING TECHNOLOGIES INTL v. IBG LLC

Before Moore, Clevenger, and Wallach.  Appeal from the Patent Trial and Appeal Board.

Summary: Claims directed to providing additional trading information on a prior art display, without more, are patent-ineligible under 35 U.S.C. § 101.

IBG and Interactive Brokers petitioned for Covered Business Method (CBM) review of a Trading Technologies (TT) patent directed to providing new or different trading information to traders via a trading screen.  The Board held the patent met the statutory definition of a “covered business method” patent and held all claims were patent-ineligible under 35 U.S.C. § 101.  TT appealed both issues.

The Federal Circuit agreed that the patent met the definition of a CBM patent because the claims failed to provide a technical solution to a technical problem.  In particular, the Federal Circuit held that providing new or different information to traders on a prior art trading screen “focuses on improving the trader, not the functioning of the computer.” 

The Federal Circuit also affirmed the claims were patent-ineligible under § 101.  Regarding step one of the Alice analysis, the claims were directed to an abstract idea because their “purported advance” was gathering, analyzing, and displaying market information without solving a technological problem.  Regarding step two, the claims failed to amount to “significantly more” than an abstract idea because they merely added conventional information to a prior art trading screen. 

Editor: Paul Stewart
 

Meet the Knobbe Martens Attorneys

Federal Circuit Affirms Patent-Ineligibility of Claims Directed to Displaying Financial Information on a Known Device
Adam Powell represents clients in a broad range of cases, including patent, antitrust, trade secret, copyright, and contract matters. He has also managed large U.S. and international...
Federal Circuit Affirms Patent-Ineligibility of Claims Directed to Displaying Financial Information on a Known Device
Douglas Wentzel assists clients with patent litigation and prosecution matters in the automotive, mechanical, and medical device spaces. Doug graduated from Drexel University, summa...
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