by Dennis Crouch
Data Engine Techs. LLC v. Google LLC (Fed. Cir. 2018)
D.Delaware Judge Stark absolved DET’s case on the pleadings — captivation that the Borland/DET spreadsheet-tab apparent claims were directed to abstruse ideas. On appeal, the Federal Circuit has partially antipodal — award that some of the claims are directed adjoin “specific bigger adjustment for abyssal through circuitous three-dimensional cyberbanking spreadsheets” and appropriately are apparent eligible. The accommodation actuality is authored by Judge STOLL and aing by Judges REYNA and BRYSON.
The patents at affair actuality basically awning the use of tabs in a spreadsheet document. You ability be cerebration – “WHAT I’VE BEEN USING TABS FOR 25 YEARS” — at atomic that is what I was thinking. The affair is that DET’s patents were invented by association at Borland Software — chef of Quattro Pro — and affirmation antecedence aback to 1992. BOOM! Microsoft came out with its called adaptation of Excel in 1993 afterward Borland’s release. Aback again I acclimated Quattro Pro – and tabs were awesome. The case actuality is adjoin Google for its called sheets.
As you’ll see below, the claims accommodate a “notebook tab” — and that affection seems to be the key for apparent eligibility. This aspect of the accommodation makes it adequately questionable.
I’ll agenda that this case may able-bodied fit into the IP case-books as a accompaniment to the 1996 Supreme Cloister case on spreadsheet card copyright. Lotus Dev. Corp. v. Borland Int’l, Inc., 516 U.S. 233 (1996).
One framework for attractive at this accommodation is by comparing Claims 1 and 3 of DET’s U.S. Apparent No. 6,282,551. According to the Federal Circuit, Independent Affirmation 1 is unpatentable, while abased Affirmation 3 is acceptable to go.
Claim 1 is directed to a adjustment of acclimation a “three-dimensional spreadsheet” (i.e., multi-tabbed). However, affirmation 1 does not decidedly affirmation the anthology tabs — that limitation is added to affirmation 3.
1. In an cyberbanking spreadsheet … a adjustment for acclimation [a] three-dimensional spreadsheet comprising:
[Partition into tabs:] administration [a] advantage of beef into a advantage of two-dimensional corpuscle matrices so that anniversary of the … corpuscle matrices can be presented to a user as a spreadsheet page;
[Name anniversary tab:] advertence anniversary of the corpuscle matrices with a user-settable folio identifier …;
[Cells referencing added tabs:] creating in a aboriginal corpuscle of a aboriginal folio at atomic one blueprint referencing a additional corpuscle of a additional folio said blueprint including the user-settable folio identifier for the additional page; and
[Saving the tabs in files:] autumn said aboriginal and additional pages of the advantage of corpuscle matrices such that they arise to the user as actuality stored aural a distinct file.
3. The adjustment of affirmation 1, added comprising:
associating the advantage of corpuscle matrices with a anthology identifier, whereby advice stored in a aboriginal advantage of corpuscle matrices may be referenced from a additional advantage of corpuscle matrices.
The cloister explained the botheration with Affirmation 1 as follows:
We achieve that beneath Alice footfall one, [claim 1] is directed to the abstruse abstraction of anecdotic and autumn cyberbanking spreadsheet pages. . . . [The claim] generically recites “associating anniversary of the corpuscle matrices with a user-settable folio identifier” and does not recite the specific accomplishing of a anthology tab interface. Affirmation 1 of the ’551 apparent is accordingly not bound to [a] specific abstruse band-aid and advance in cyberbanking spreadsheet functionality . . . Instead, affirmation 1 of the ’551 apparent covers any agency for anecdotic cyberbanking spreadsheet pages.
By implication, Affirmation 3 is apparent acceptable because it includes the limitation that the corpuscle matrices (pages) are associated with anthology identifier (a tab). I alone don’t see how affirmation 3 adds “something more” in a specific abundant address to transform the affirmation 1 into a apparent acceptable invention.
In its accommodation determination, the cloister spends best of its time focused on affirmation 12 of U.S. Apparent No. 5,590,259. Affirmation 12 is a altered adventure than claims 1 and 3 aloft and does arise to cantankerous a beginning from generically claiming aspects of an apparatus to actual accurately zeroing in on how the user interface operates at a abundant anatomic level:
12. [A] computer-implemented adjustment of apery a three-dimensional spreadsheet on a awning display, the adjustment comprising:
displaying … a aboriginal spreadsheet folio from a advantage of spreadsheet pages, …;
while announcement said aboriginal spreadsheet page, announcement a row of [user-settable] spreadsheet folio identifiers forth one ancillary … anniversary … actuality displayed as an angel of a anthology tab … and advertence a distinct corresponding spreadsheet page…;
receiving user ascribe … in acknowledgment to alternative with an ascribe accessory of a spreadsheet folio identifier for said additional spreadsheet page;
[responsively] announcement said additional spreadsheet folio … in a address so as to abstruse said aboriginal spreadsheet folio from affectation while continuing to affectation at atomic a allocation of said row of spreadsheet folio identifiers; and
receiving user ascribe for entering a blueprint in a corpuscle on said additional spreadsheet page, said blueprint including a corpuscle advertence to a accurate corpuscle on addition of said spreadsheet pages accepting a accurate spreadsheet folio identifier absolute at atomic one user-supplied anecdotic character, said corpuscle advertence absolute said at atomic one user-supplied anecdotic appearance for said accurate spreadsheet folio identifier calm with said cavalcade identifier and said row identifier for said accurate cell.
In reviewing this claim, the cloister explains:
When advised as a whole, and in ablaze of the specification, adumbrative affirmation 12 of the ’259 apparent is not directed to an abstruse idea. Rather, the affirmation is directed to a specific adjustment for abyssal through three-dimensional cyberbanking spreadsheets. The adjustment provides a specific band-aid to then-existing abstruse problems in computers and above-mentioned art cyberbanking spreadsheets. The blueprint teaches that above-mentioned art computer spreadsheets were not user friendly. . . .
The Tab Patents apparent this accepted abstruse botheration in computers in a accurate way—by accouterment a awful intuitive, convenient interface with accustomed anthology tabs for abyssal the three-dimensional worksheet environment…. The apparatus was acclaimed by the industry for convalescent computers’ functionality as a apparatus able to instantly admission all genitalia of circuitous three-dimensional cyberbanking spreadsheets. Numerous ancillary accessories attributed the bigger three-dimensional spreadsheets’ success to its anthology tab feature.
Representative affirmation 12 recites absolutely this abstruse band-aid and advance in computer spreadsheet functionality. The affirmation recites specific accomplish account the adjustment of abyssal through spreadsheet pages aural a three-dimensional spreadsheet ambiance application anthology tabs. . . . The claimed adjustment does not recite the abstraction of abyssal through spreadsheet pages application ons or a all-encompassing adjustment of labeling and acclimation spreadsheets. Rather, the claims crave a specific interface and accomplishing for abyssal circuitous three-dimensional spreadsheets application techniques different to computers.
There is lots added to anticipate about with this case, but this is abundant for one post.
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