Fort Properties, Inc. v. American Master Lease, LLC

Simply adding a “computer aided” limitation to a claim covering an abstract concept, without more, is insufficient to render the claim patent eligible.

Opinon (Prost): Master Lease LLC (“American”) sought review of an order of the U.S. District Court for the Central District of California granting summary judgment in favor of Fort Properties, Inc. (“Fort”), finding American’s claims in the patent at issue failed to meet subject matter eligibility requirements. The patent at issue disclosed an investment tool designed to enable property owners to buy and sell properties without incurring tax liability. The Court cited 35 U.S.C. 101, which specifies four independent categories of inventions or discoveries that are eligible for protection: machines, manufactures, compositions of matter, and processes. The Court also noted the three exceptions to the broad patent-eligibility principles: laws of nature, physical phenomena, and abstract ideas. At issue was whether the investment tool falls under the ‘process’ category. The court found that 35 U.S.C. 100(b) of the Patent Act defines ‘process’ to mean process, art, or method, and includes a new use of a known process, machine, manufacture, composition of matter, or material. The court found this claimed method of aggregating property – making it subject to an agreement, and then issuing ownership interests to multiple parties consisted entirely of mental processes and abstract intellectual concepts – ineligible for patent protection, thereby AFFIRMING the decision of the district court.