In the ongoing case of Inmar Brand Solutions, Inc. v.
Quotient contends that the patents asserted by
As explained by the district court, the primary concern underlying this argument is the concept of preemption, which aims to prevent the granting of a monopoly over an abstract idea that could impede innovation. While the Supreme Court in Alice did not provide precise contours for what constitutes an abstract idea, subsequent Federal Circuit decisions have shed light on this issue.
An abstract idea is at issue when the claimed advance is “a method of organizing human activity.” Alice, 573 U.S. at 220. A telltale sign of abstraction is when claimed functions are mental processes that can be performed using only human cognition or simple tools like pencil and paper. For instance, a poll-based networking system that connects users based on similarities determined through poll answering was deemed abstract because it did not improve existing technology and did not require specialized computer components.
The district court further explained that not all systems that automate tasks previously performed by humans necessarily fall into the abstract idea category. For example, a patent directed to an improved system for washing jet engines was held to be non-abstract because it provided technical improvements over prior art systems.
In its ruling, the district court acknowledges the validity of Quotient's concerns regarding preemption and the potential stifling of innovation. Nonetheless, the district court concludes that
For that reason, the district court did not proceed to step two of Alice and denied the motion to dismiss.
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