CAFC on computer claims in DealerTrack

The U.S. Court of Appeals for the Federal Circuit released a decision today in DealerTrack v. Huber on the patentability of computer claims. It held that claims “for executing a computer program” were means-plus-function limited to the algorithms in the specification and “computer aided” limitations did not render claims patentable subject matter.

In the context of a patent infringement action regarding U.S. 6,587,841 and US7,181,427, the Court held that claims to “central processing means, operably coupled to said communications medium, for executing a computer program which implements and controls credit application processing and routing ” were means-plus-function claims were limited to structure that “must include the algorithms disclosed in the specification that “implement[] and control[] credit application processing and routing.”

Regarding §101 objections to the 427 patent, the a majority held that the claims were not directed to patentable subject matter. The Court said that “Simply adding a “computer aided” limitation to a claim covering an abstract concept, without more, is insufficient to render the claim patent eligible.”

Justice Plager concurred-in-part and dissented-in-part, writing that courts should “not foray into the jurisprudential morass of §101 unless absolutely necessary” and instead focus on obviousness and anticipation first. Justice Plager would have remanded the decision to the lower court to decide the issues of obviousness prior to determining patentability under §101.