Patent's Description of Technological Solutions to Prior Art Problems Overcomes Early §101 Invalidity

On March 5, 2019, Judge Gary Feinerman denied defendant Card Concepts' (CCI) Federal Rules of Civil Procedure motion for judgment on the pleadings that the patent claims are invalid as unpatentable subject matter pursuant to Section 101 in this patent case involving systems for collecting payments across different networks, particularly for laundromat systems.

Citing Aatrix and looking to the patent's specification and the complaint, the Court held that the patent and plaintiff Upaid's complaint identified the development of the patented invention and the improvements over the prior art. They also explained how the patent enabled operation of advanced communications regardless of hardware limitations. In light of the statements in the patent and the complaint, the Court could not hold the patent invalid as unpatentable at the pleading stage.

The case is: Upaid Sys., Ltd. v. Card Concepts, Inc., No. 17 C 8150, Slip Op. (N.D. Ill. Mar. 25, 2019) (Feinerman, J.).

This blog was originally published by Chicago IP Litigation.