Fed. Cir. Agrees: Patent Directed to Monitoring Baggage Delivery is an Invalid Abstract Idea
Earlier this month, the Federal Circuit affirmed another District of Delaware decision without a written opinion. The Delaware decision, from January 2019, granted Roadie, Inc.'s motion for judgment on the pleadings, finding plaintiff's asserted patent to be an invalid abstract idea.
The asserted patent related to an apparatus, method and system for dispatching baggage. Roadie argued that the asserted claims were directed to the abstract idea of "coordinating and monitoring baggage delivery." Both the district court and the Federal Circuit agreed.
The representative claim can be summarized as follows: (1) receiving baggage information, (2) assigning the baggage to a delivery person, (3) informing the passenger that the baggage is on its way and who is delivering it, (4) receiving a request to delay delivery, (5) informing the delivery person of the change and (6) reordering the delivery person's delivery schedule. The district court found that this is nothing more than coordinating and monitoring baggage delivery, which is a well-known method of organizing human activity.
Plaintiff argued that the asserted patent claims were directed to a new and useful technique for performing a particular task. The court disagreed. While the patent specification states that the invention relates to "improved systems and methods for coordinating and monitoring baggage delivery," the claims merely take "the traditional method of baggage delivery and executed it using generic and non-specific hardware and software."
At step two of the Alice inquiry, the plaintiff pointed to the specification's statement that an advantage of the invention is that the delivery of the baggage is guaranteed. The claims, however, do not require delivery of the baggage to occur, "much less that the delivery is guaranteed." The court emphasized that the focus of the Section 101 inquiry is the claims.
The plaintiff also argued that the claimed computing devices are configured in a way that baggage information could be communicated more efficiently. The court again disagreed. Instructing one to "apply" an abstract idea and reciting no more than generic computer elements performing generic computer tasks does not make an abstract idea patent-eligible. Similarly, reciting generic computer functions to achieve a more efficient way of coordinating and monitoring baggage delivery does not make the claims patent-eligible.
In the end, another monitoring patent falls.