This section contains summaries of July 2020 decisions of the Patent Trial and Appeal Board (PTAB) concerning 35 U.S.C. Section 101, which sets forth the four categories of patent-eligible subject matter: process, machines, manufactures, and compositions of matter. Two Section 101 decisions are summarized.
Ex Parte Pahls et al; 7/8/2020; TC 3600; Real party in interest, Piscore, Inc. The Preamble of claim 1 recited a method of displaying an electronic polling request on a graphical user interface and receiving scoring information from a user. The Board determined that the judicial exception―a mental process―was integrated into a practical application. The claimed method of laying layer over an image provided a specific technological improvement over prior electronic polling graphical user interfaces. The claimed method provided an improved electronic polling graphical user interface that allowed a user to click on an image and thus input his subjective evaluation of the image in two criteria simultaneously, using a transparent layer laid over the image, the invention allowing for faster user input than previously possible and on smaller user screens such as mobile phones than were possible using previous electronic polling techniques. Section 101 rejections REVERSED.
Ex Parte Danielak et al; 7/1/2020; TC 3600; Real party in interest, Toronto-Dominion Bank. The claimed invention related to methods and systems that identified and remedied shortfall events associated with stored account data operated by financial institutions. Section 101 rejections affirmed.