In reviewing a district court’s grant of summary judgment in favor of a defendant on the basis of patent ineligible subject matter, the Federal Circuit has affirmed.
The method at issue involved steps of a borrower applying for a loan, a third party calculating a credit grading, lenders providing loan pricing, and then the borrower disclosing its identity to the lender. The Federal Circuit concluded that the claim was directed to an abstract idea because “The series of steps covered by the asserted claims … could all be performed by humans without a computer.”
The Federal Circuit also held that no inventive concept was included, because the rest of the claim was directed to generic computer components, which do not satisfy the inventive concept requirement.
http://www.cafc.uscourts.gov/sites/default/files/opinions-orders/15-1415.Opinion.1-15-2016.1.PDF