DATA ENGINE TECH. LLC v. GOOGLE LLC

DATA ENGINE TECH. LLC v. GOOGLE LLC, Appeal No. 2017-1135 (Fed. Cir. October 9, 2018) (Reyna, Bryson, and Stoll).  Appealed from D. Del. (Judge Stark).  (Patent Eligibility)

Background:

Data Engine Tech. (DET) is the owner of the four patents-in-suit. Three of the four patents (collectively, the Tab patents) are directed to methods of navigating through complex three-dimensional electronic spreadsheets.  The Tab patents use notebook tabs as interface objects to navigate through multiple pages of spreadsheets to improve the conventional process of searching for, memorizing, and entering complex commands.  The fourth patent (‘146 patent) is directed to methods for tracking changes to data in spreadsheets by creating and tracking various versions of a data model set in a spreadsheet.

DET filed an infringement suit against Google, and Google filed a motion for judgment on the pleadings arguing that all of DET’s patents are invalid under 35 U.S.C. §101.  The district court granted the motion reasoning that the Tab patents were directed to the abstract idea of using notebook-type tabs to label and organize spreadsheets, and the ‘146 patent was directed to the abstract idea of collecting spreadsheet data, recognizing changes to the spreadsheet data, and storing information about the changes.  DET appealed.

Issues/Holdings:

Did the district court err in granting the motion finding the Tab patents ineligible under 35 U.S.C. §101?

Did the district court err in granting the motion finding the ‘146 patent ineligible under 35 U.S.C. §101? (continue reading).

Summary by:  Matt Stanford

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