Intellectual Ventures I LLC v. Capital One Fin. Corp.

Patentability and Indefiniteness: A method that manipulates or reorganizes data is merely an abstract idea that is not subject to patentability. In applying an idea to a specific machine, the term "interactive interface" requires some standard to avoid being too indefinite and losing patent protection.

Opinion (Tengra): Intellectual Ventures I, LLC and Intellectual Ventures II, LLC claimed that Capital One Financial Corporation infringed two of its patents. The first patent "utilizes user-selected pre-set limits on spending that are stored in a database that, when reached, communicates a notification to the user via a device." The second patent was described as "a system for delivering information from an information provider to an information user that is selectively tailored toward the capabilities of the information provider and the needs of the information user." The Court issued a claim construction order, and Capital One filed a motion for summary judgment. Capital One argued that both patents are unpatentable abstract ideas. Capital One also contended that the second patent was too indefinite because it did not "sufficiently apply this idea through any specific machine." Based on a clear and convincing evidence, the Court concluded as a matter of law that neither patents contained patentable subject matter under 35 USCS § 100. "At most, the patents describe a more efficient system or method for performing tasks than could be done without a computer.” Additionally, the court ruled that the term "interactive interface," as used in the second patent, lacked standards and was too indefinite to put the public on notice as to the subject matter protected by the patent. The Court GRANTED Capital One's motion for summary judgment and dismissing the action.