A system claim which includes as a limitation a computer to perform steps in a method is ineligible for patent protection under 35 U.S.C. §101 as a claim to an abstract idea because the computer functions solely as an obvious mechanism to solve a problem quickly, the Federal Circuit held July 26, 2012. Bancorp Services, L.L.C. v. Sun Life Assurance Company of Canada (U.S.), Fed. Cir., No. 2011-1467, 7/26/12.
The asserted patents are directed to systems and methods for
administering and tracking the value of life insurance policies in
separate accounts. The Federal Circuit affirmed a district court summary
judgment that the patents are ineligible for patent protection
because the claimed computer components are no more than objects that
facilitate the operation of claimed methods directed to an abstract
idea. It held that a machine, system, medium, or the like may in some
cases be equivalent to an abstract mental process
for purposes of patent ineligibility.
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