Formula for Abstract Ideas: Alice Applied to Spreadsheet Claims with Mixed Results
Addressing whether patent claims were directed to abstract ideas, the US Court of Appeals for the Federal Circuit found that a number of claims directed to organizing and presenting information in electronic spreadsheets were patent eligible while other claims were ineligible. Data Engine Techs. LLC v. Google LLC, Case No. 17-1135 (Fed. Cir. Oct. 9, 2018) (Stoll, J). The Court followed the now-familiar two-step Alice test for determining (1) whether the claims were directed to a patent-ineligible concept and (2) if so, whether the combination of elements transformed the nature of the claim into a patent-eligible application of the concept.
Multiple claims from four patents were at issue in the appeal, and the Federal Circuit discussed three representative claims. One representative claim related to navigating through three-dimensional electronic spreadsheets. A second representative claim related to creating a tabbed spreadsheet where the tabs can be named by the user to serve as the page’s unique identifier. A third representative claim related to tracking modifications across multiple sheets of a three-dimensional electronic spreadsheet.
The district court found that all of the claims were directed to the abstract ideas of “using notebook-type tabs to label and organize spreadsheets” or “collecting spreadsheet data, recognizing changes to spreadsheet data, and storing information about the changes.” The district court entered a judgment on the pleadings finding all of the asserted claims invalid.
On appeal and under a de novo review, the Federal Circuit characterized the first representative claim differently, finding that it was not directed to an abstract idea under Alice step 1. Instead, the Court determined that the claim was directed to a specific method for navigating through electronic spreadsheets that required a specific interface and a particular implementation. Relying on the specification description of the alleged benefits of the invention and on industry praise that had been submitted during prosecution, the Court determined that the claimed method solved a known technical problem in a particular way, and it analogized the claims to those it had found eligible in Core Wireless (IP Update, Vol. 21, No. 9) and Trading Technologies International, Inc. v. CQG, Inc. (IP Update, Vol. 20, No. 2).
As to the other two representative claims, the Federal Circuit determined that under Alice step 1, the claims were directed to abstract ideas because they were generic recitations of identifying/storing information in an electronic spreadsheet or tracking changes to an electronic spreadsheet—not limited to a specific technical solution as with the first representative claim. In the Alice step 2 part of the analysis, the Court found that the claims lacked any inventive concept and did little more than restate the abstract idea itself.