Cybersource Corporation v. Retail Decisions, Inc.

A method that can be performed by human thought alone is merely an abstract idea and is not patent-eligible because computational methods that can be performed entirely in the human mind embody basic tools of scientific work that are free to all men and reserved exclusively to none.

For full opinion:
2011 U.S.Dist.LEXIS 16871
2011 WL 3584472

Opinion (Dyk): Cybersource Corporation (“Cybersource”) appealed the decision of the U.S. Northern District Court of California granting summary judgment of invalidity of two patent claims for failure to recite patent-eligible subject matter to a competitor, Retail Decisions, Inc., (“Retail”). Cybersource owned by assignment a patent which recited a method and system for detecting fraud in a credit card transaction between a consumer and a merchant over the internet, and brought suit against Retail for alleged infringement. The patent claim describes a method for verifying the validity of a credit card transaction over the internet, including constructing a map of credit card numbers based upon all of the transactions and utilizing the map of credit card number to determine if the credit card transaction is valid. The Supreme Court has stated that phenomena of nature, though just discovered, mental processes, and abstract intellectual concepts are not patentable, as they are the basic tools of scientific and technological work. Here, the court found that because one could mentally perform the fraud detection method that underlies the claims of the patent in dispute, the claims attempt to capture unpatentable mental processes, and are therefore invalid. The decision of the District Court was therefore AFFIRMED.