The Court of Appeals for the Federal Circuit reversed a district court decision and found that certain patent claims were directed to patent-eligible subject matter. “The[] claims are not abstract, but rather are directed to a specific improved method for navigating through complex three-dimensional electronic spreadsheets.” Other “claims of the [] patent, reciting methods for tracking changes to data in spreadsheets, are directed to the abstract idea of collecting, recognizing, and storing changed information” and are not patent eligible subject matter. Data Engine Technologies LLC v. Google LLC, Case No. 2017-1135 (Fed. Cir. Oct. 9, 2018) (pdf opinion available here).
Data Engine Technologies appealed the district court’s entry of judgment on the pleadings holding that the asserted claims of are ineligible under 35 U.S.C. § 101. The Federal Circuit “conclude[d] that, with the exception of claim 1 of the ’551 patent, the asserted claims of the ’259, ’545, and ’551 patents (“Tab Patents”) are directed to patent-eligible subject matter. These claims are not abstract, but rather are directed to a specific improved method for navigating through complex three-dimensional electronic spreadsheets. We agree, however, that the asserted claims of the ’146 patent, reciting methods for tracking changes to data in spreadsheets, are directed to the abstract idea of collecting, recognizing, and storing changed information.”
The Tab Patents claim systems and methods for making complex electronic spreadsheets more accessible by providing familiar, user-friendly interface objects—specifically, notebook tabs—to navigate through spreadsheets while circumventing the arduous process of searching for, memorizing, and entering complex commands. Specifically, the Tab Patents are directed to and claim a method of implementing a notebook-tabbed interface, which allows users to easily navigate through three-dimensional electronic spreadsheets.
In this preferred embodiment, “each page identifier is in the form of a tab member (e.g., members 261a, 262a, 263a) situated along a bottom edge of the notebook.” Although these tabs are labeled A, B, and C, etc., they are typically given descriptive names assigned by the user. To move to different spreadsheet pages, the user selects the corresponding tab for that page. Thus, “instead of finding information by scrolling different parts of a large spreadsheet, or by invoking multiple windows of a conventional three-dimensional spreadsheet, the present invention allows the user to simply and conveniently ‘flip through’ several pages of the notebook to rapidly locate information of interest.” This improved interface allows for “rapidly accessing and processing information on the different pages, including, for example, displaying a plurality of page identifiers for selecting individual pages.”
Claim 12 illustrates these concepts: 12. In an electronic spreadsheet system for storing and manipulating information, a computer implemented method of representing a three-dimensional spreadsheet on a screen display, the method comprising: [a] displaying on said screen display a first spreadsheet page from a plurality of spreadsheet pages, each of said spreadsheet pages comprising an array of information cells arranged in row and column format, at least some of said information cells storing user-supplied information and formulas operative on said user-supplied information, each of said information cells being uniquely identified by a spreadsheet page identifier, a column identifier, and a row identifier; [b] while displaying said first spreadsheet page, displaying a row of spreadsheet page identifiers along one side of said first spreadsheet page, each said spreadsheet page identifier being displayed as an image of a notebook tab on said screen display and indicating a single respective spreadsheet page, wherein at least one spreadsheet page identifier of said displayed row of spreadsheet page identifiers comprises at least one usersettable identifying character; [c] receiving user input for requesting display of a second spreadsheet page in response to selection with an input device of a spreadsheet page identifier for said second spreadsheet page; [d] in response to said receiving user input step, displaying said second spreadsheet page on said screen display in a manner so as to obscure said first spreadsheet page from display while continuing to display at least a portion of said row of spreadsheet page identifiers; and [e] receiving user input for entering a formula in a cell on said second spreadsheet page, said formula including a cell reference to a particular cell on another of said spreadsheet pages having a particular spreadsheet page identifier comprising at least one user-supplied identifying character, said cell reference comprising said at least one user supplied identifying character for said particular spreadsheet page identifier together with said column identifier and said row identifier for said particular cell.
Another Patent Claims was held to be not patent eligible subject matter recites: 1. In an electronic spreadsheet system for modeling user-specified information in a data model comprising a plurality of information cells, a method for automatically tracking different versions of the data model, the method comprising: (a) specifying a base set of information cells for the system to track changes; (b) creating a new version of the data model by modifying at least one information cell from the specified base set; and (c) automatically determining cells of the data model which have changed by comparing cells in the new version against corresponding ones in the base set.
Patent eligible claim 12 recites “precisely this technical solution and improvement in computer spreadsheet functionality. The claim recites specific steps detailing the method of navigating through spreadsheet pages within a three-dimensional spreadsheet environment using notebook tabs. The claim requires displaying on a screen display a row of spreadsheet page identifiers along one side of the first spreadsheet page, with each spreadsheet page identifier being a notebook tab. The claim requires at least one user-settable identifying character to label the notebook tab and describes navigating through the various spreadsheet pages through selection of the notebook tabs. The claim further requires a formula that uses the identifying character to operate on information spread between different spreadsheet pages that are identified by their tabs. The claimed method does not recite the idea of navigating through spreadsheet pages using buttons or a generic method of labeling and organizing spreadsheets. Rather, the claims require a specific interface and implementation for navigating complex three-dimensional spreadsheets using techniques unique to computers.”
Claim 12 is similar to the claims the Court held patent eligible in Core Wireless. “There, the claims were directed to an improved display interface that allowed users to more quickly access stored data and programs in small-screen electronics, thereby improving the efficient functioning of the computer. Core Wireless S.A.R.L. v. LG Elecs., Inc., 880 F.3d 1356, 1359 (Fed. Cir. 2018). Core Wireless’s invention, however, improved the efficiency of these display interfaces. By displaying only a limited list of common functions and data from which to choose, the invention spared users from time consuming operations of navigating to, opening up, and then navigating within, each separate application. Id. The invention thus increased the efficiency with which users could navigate through various views and windows.”
“Likewise, claim 12 comports with the claims we held patent eligible in Trading Technologies International, Inc. v. CQG, Inc. 675 F. App’x 1001 (Fed. Cir. 2017). There, the claims recited a trading system in which a graphical user interface displayed dynamic bid and ask prices for a particular commodity traded in the market along with a static display of prices corresponding to the bids and asks. Id. at 1003. The system paired orders with the static display of prices to prevent entry of orders that had changed prices. Id. The patents explained that the invention solved an existing problem in the prior art by reducing the time it took to place and execute a trading order. We agreed with the district court that “the challenged patents ‘solve[d] problems of prior graphical user interface devices . . . in the context of computerized trading[] relating to speed, accuracy and usability.’” As the district court had explained, the claims were not merely directed to displaying information on a graphical user interface, but rather “require[d] a specific, structured graphical user interface paired with a prescribed functionality directly related to the graphical user interface’s structure that is addressed to and resolves a specifically identified problem in the prior state of the art.” Id. We agreed and adopted the district court’s articulated reasons to conclude that the claims were not abstract under Alice step one. Id.”
In contrast to Affinity Labs, Capital One, and Erie Indemnity, representative claim 12 is not simply directed to displaying a graphical user interface or collecting, manipulating, or organizing information to improve navigation through three-dimensional spreadsheets. “Instead, the claim recites a specific structure (i.e., notebook tabs) within a particular spreadsheet display that performs a specific function (i.e., navigating within a three-dimensional spreadsheet).”
However, with respect to claim 1 set forth below, the Court held that the claim was patent ineligible. Claim 1 recites: 1. In an electronic spreadsheet for processing alphanumeric information, said . . . electronic spreadsheet comprising a three-dimensional spreadsheet operative in a digital computer and including a plurality of cells for entering data and formulas, a method for organizing the three-dimensional spreadsheet comprising: [a] partitioning said plurality of cells into a plurality of two-dimensional cell matrices so that each of the two-dimensional cell matrices can be presented to a user as a spreadsheet page; [b] associating each of the cell matrices with a user-settable page identifier which serves as a unique identifier for said each cell matrix; [c] creating in a first cell of a first page at least one formula referencing a second cell of a second page said formula including the user-settable page identifier for the second page; and [d] storing said first and second pages of the plurality of cell matrices such that they appear to the user as being stored within a single file.
After a searching review, the additional elements of claim 1 above fail to provide an inventive concept. Claim 1 merely recites partitioning cells to be presented as a spreadsheet, referencing in one cell of a page a formula referencing a second page, and saving the pages such that they appear as being stored as one file. These limitations merely recite the method of implementing the abstract idea itself and thus fail under Alice step two. Therefore, we conclude that claim 1 is ineligible under § 101.
