CYBERSOURCE CORPORATION, Plaintiff-Appellant, v. RETAIL DECISIONS, INC., Defendant-Appellee., 654 F.3d 1366

Summary

The patentee owned a patent aimed at detecting fraud in a credit card transaction between a consumer and a merchant over the Internet. The patentee brought an infringement suit against a competitor and the competitor defended on the basis of invalidity under 35 U.S.C.S. § 101. The district court granted summary judgment of invalidity finding that the patent claims merely recited an unpatentable mental process for collecting data. More specifically, the district court concluded that the mere collection and organization of data regarding credit card numbers and Internet addresses was insufficient to meet the transformation prong of the machine-or-transformation test test, and the patent claims did not require the method to be performed by a particular machine, or even a machine at all. The appellate court agreed with that analysis and concluded that one could mentally perform the fraud detection method described in the claims as the method consisted of only a general approach of ...