PTAB Finds Business Method Claims Reciting “Generic Computer Technology” Unpatentable Under 35 U.S.C. § 101
In CRS Advanced Technologies, Inc. v. Frontline Technologies, Inc. (CBM2012-00005, Paper No. 66, entered January 21, 2014), a transitional covered business method (CBM) review, the Patent Trial and Appeal Board (PTAB) held all instituted claims 3, 6, 7, 16, 24 and 33 of U.S. Patent No. 6,675,151 C1 (“the ‘151 patent”) unpatentable under § 101. Id. at 3.
Petitioner Winning Streak Continues as PTAB Cancels All Reviewed Claims in Liberty Mutual Final Decisions
In two final decisions dated January 23, 2014, the Patent Trial and Appeal Board (PTAB) canceled all reviewed claims of U.S. Patent No. 6,064,970, including both a single claim that the PTAB found to be directed to a business method and the patent’s other claims. Liberty Mutual Insurance Co. v. Progressive Casualty Insurance Co., (CBM2012-00002, Paper No. 66 and CBM2014-00004, Paper No. 60). The final decisions were entered 363 days after the PTAB had instituted the covered business method (CBM) reviews of the ‘970 patent, meeting the 35 U.S.C. § 326(a)(11) requirement for a final determination within one year of the trial being instituted by two days.