“Abstract Idea” Expands, Now Includes Back-and-Forth Browser Functionality

Author: Sean D. Damon
Editor: Lauren J. Dreyer

In Internet Patents v. Active Network, No. 14-1048 (Fed. Cir. June 23, 2015), the Federal Circuit affirmed yet another invalidity ruling for lack of patentable subject matter under 35 U.S.C. § 101. The asserted patent was filed in 2000 and used a conventional web browser’s Back-and-Forward navigational functionalities without data loss in an online application with dynamically generated web pages.

On appeal, the Court held that the asserted claims were directed to an abstract idea: retaining information in the navigation of online forms. The Court noted that while claim 1 was directed to “maintaining” the state of user input upon “activation” of another icon (or tab), the “mechanism for maintaining the state is not described, although this is stated to be the essential invention.”  The additional elements of the dependent claims did not add the necessary “inventive concept” because they represented “generic data collection steps or siting the ineligible concept in a particular technological environment.”

DISCLAIMER: Although we wish to hear from you, information exchanged in this blog cannot and does not create an attorney-client relationship. Please do not post any information that you consider to be personal or confidential. If you wish for Finnegan, Henderson, Farabow, Garrett & Dunner, LLP to consider representing you, in order to establish an attorney-client relationship you must first enter a written representation agreement with Finnegan. Contact us for additional information.

Tagged

Leave a Reply

Fill in your details below or click an icon to log in:

WordPress.com Logo

You are commenting using your WordPress.com account. Log Out / Change )

Twitter picture

You are commenting using your Twitter account. Log Out / Change )

Facebook photo

You are commenting using your Facebook account. Log Out / Change )

Google+ photo

You are commenting using your Google+ account. Log Out / Change )

Connecting to %s

%d bloggers like this: