The Federal Circuit made quick work of applying the two step Alice inquiry to a patent application describing a method “enabling the sale of products or services which are available on the internet.” In five pages, the court’s In re Elbaum opinion quickly affirmed the PTAB’s determination that the claimed invention (1) is directed to “an abstract idea, a commercial transaction that amounts to a method of organizing human activity,” and (2) recites “purely conventional computer functions of storing, receiving, analyzing, and processing data.” The court explained “[i]f anything, the claim recites generic computer functions, which the specification describes are carried out by conventional computer components.” While court’s opinion is nonprecedential and by no means groundbreaking, it is a good reminder that Alice is alive and well.
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