Intellectual Ventures I LLC v. Capital One Financial Corp., No. 16-1077 (Fed. Cir. 2017)
Annotate this CaseIV sued Capital One, alleging infringement of three patents. Capital One asserted antitrust counterclaims against IV under the Sherman Act and moved for summary judgment on IV’s infringement claims, arguing that the 081 and 002 patents were invalid under 35 U.S.C. 101. In a related proceeding, the district court entered a partial summary judgment order of ineligibility under section 101 for the 084 patent. The district court invalidated the 081 and 002 patents under section 101 and barred IV from proceeding on its infringement claims as to the 084 patent under a collateral estoppel theory. The Federal Circuit, having affirmed in the related proceeding, also affirmed in favor of Capital One. The partial summary judgment order with respect to the 084 patent met the finality prong for the purposes of collateral estoppel. The claims of the 081 patent are, at their core, directed to the abstract idea of collecting, displaying, and manipulating data, and are patent-ineligible; taken individually or in combination, the recited limitations neither improve the functions of the computer itself, nor provide specific programming, tailored software, or meaningful guidance for implementing the abstract concept. The court noted that the 002 patent had been found ineligible in a related proceeding.
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