Dealertrack, Inc. v. Huber
674 F.3d 1315
Fed. Cir.2012Background
- Dealertrack owns the '841 and '427 patents on computer-aided credit applications over electronic networks.
- The district court construed 'communications medium' to exclude the Internet, supporting summary judgment of non-infringement of the '841 Patent.
- The district court also held all asserted claims of the '427 Patent invalid under §101 and denied invalidity for priority issues.
- RouteOne cross-appealed, arguing indefiniteness of claims 14, 16, and 17 of the '841 Patent.
- The Federal Circuit vacated in part, affirmed-in-part, reversed-in-part, and remanded to address constructions and infringement consistent with its opinion.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Does Internet fall within 'communications medium'? | Dealertrack: Internet is a communications medium in 1995. | Appellees: Internet excluded; not reliable/secure; not intended by prosecution. | Communication medium includes Internet; district court error vacated and remanded. |
| How should 'routing' be construed? | Routing includes sequencing/timing; described as multiple, optional schemes. | Routing limited to sending by a route; timing/order not essential. | Affirmed district court's routing construction; reading 'i.e.' as exemplary to include multiple schemes. |
| How should 'central processing means' be construed in means-plus-function sense? | Algorithms in Figures 2, 2B, 2C-1/2C-2, 2D provide structure. | General computer plus database suffices; algorithms not necessary to limit claim. | Structure must include disclosed algorithms; claims narrowed; remanded for infringement analysis. |
| Are claims 1, 3, 4 of the '427 Patent patent ineligible under §101? | Claims tie to concrete, non-abstract processing of credit applications. | Claims abstract; general computer implementation; preempts clearinghouse concept. | Claims 1, 3, 4 invalid as abstract ideas under §101. |
| Should indefiniteness be affirmed for tracking feature in the '841 Patent? | Algorithms disclosed in specification cover tracking function. | No disclosed algorithm for tracking; indefinite. | Indefiniteness affirmed; district court erred in denying invalidity. |
Key Cases Cited
- Phillips v. AWH Corp., 415 F.3d 1303 (Fed. Cir. 2005) (claims not limited to specific embodiments; non-exhaustive lists may broaden scope)
- Bilski v. Kappos (Bilski II), 130 S. Ct. 3218 (S. Ct. 2010) (§101 threshold; abstract ideas preemption concerns)
- Aristocrat Techs. Austl. Pty Ltd. v. Int'l Game Tech., 521 F.3d 1328 (Fed. Cir. 2008) (means-plus-function requires specific structure; pure functional claiming barred)
- WMS Gaming, Inc. v. Aristocrat, 305 F.3d 1337 (Fed. Cir. 2002) (distinct and alternative structures may perform claimed function)
- Enzo Biochem, Inc. v. Applera Corp., 599 F.3d 1325 (Fed. Cir. 2010) (written description must support claimed structure)
- Biomedino, LLC v. Waters Techs. Corp., 490 F.3d 946 (Fed. Cir. 2007) (structure must limit means-plus-function claims)
- Diamond v. Diehr, 450 U.S. 175 (U.S. 1981) (industrial process flexibility and machine transformation relevance)