SAP AMERICA, INC. V. INVESTPIC LLC

InvestPic’s U.S. Patent No. 6,349,291 relates to systems and methods for performing certain statistical analyses of investment information. The CAFC previously construed key claim terms and partly reversed and partly vacated the PTAB’s cancellations of various claims in two reexamination proceedings involving issues of anticipation and obviousness. In this appeal, SAP America alleges, among other things, that the claims of the ’291 patent are invalid because their subject matter is ineligible for patenting under 35 U.S.C. § 101. When SAP moved for a judgment on the pleadings on that ground, the district court granted the motion, holding all claims ineligible under § 101 and hence invalid. The CAFC affirms, noting that no matter how much of an advance in the finance field, the subject matter of the claims is nothing but a series of mathematical calculations based on selected information and the presentation of the results of those calculations (in the plot of a probability distribution function). 

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