The Federal Circuit has affirmed a summary judgement finding that a patent asserted against Amazon was invalid for being directed into ineligible subject matter.
Rensselaer Polytechnic Institute and CF Dynamic Advances LLC (together, “Rensselaer”) brought suit against Amazon.com, Inc. for alleged infringement of United States Patent No. 7,177,798.
The ’798 patent discloses a “method for processing a natural language input provided by a user.”
Claim 1 of the patent recites:
1. A method for processing a natural language input provided by a user, the method comprising:
providing a natural language query input by the user;
performing, based on the input, without augmentation, a search of one or more language-based databases including at least one metadata database comprising at least one of a group of information types comprising:
case information;
keywords;
information models; and
database values;providing, through a user interface, a result of the search to the user;
identifying, for the one or more language-based databases, a finite number of database objects; and
determining a plurality of combinations of the finite number of database objects.
Rensselaer argued that the patent is “directed to the novel application of case-based reasoning to a metadata database within [natural language processing].”
Rensselaer said that case-based reasoning is “an established problem-solving technique for computers,” and, when applied to the field of natural language processing, it uses “case information to learn from metadata associated with past utterances” to resolve the natural ambiguities existing in human language, such as when one word carries multiple meanings.
In doing this, said Rensselaer, “the claimed method can process an input of natural human language without needing to first augment the input by translating it into a more easily readable syntax.
In short, explained the court, “case-based reasoning is, in the context of this patent, a type of machine learning or artificial intelligence (“AI”).”
The Supreme Court has concluded that certain things can’t be patented: “laws of nature, natural phenomena, and abstract ideas.”
In evaluating a software patent, noted the Federal Circuit, the inquiry often examines “whether the claims focus on a specific technological improvement to computer capabilities or merely invoke computers as a tool that implements an abstract idea.”
The court explained that
We have consistently concluded that claims that use “functional, result-focused language” or merely “encompass ordinary computers and networks to perform their ordinary functions in carrying out an abstract idea, even when narrowed to a particular use or environment,” do not provide an inventive concept capable of rendering the claims patent eligible.
Instead, said the court, the claims must “require a specific implementation to improve how those functions are carried out.”
The district court determined that the patent claims in this case were directed to an abstract idea, and the Federal Circuit agreed.
Said the Federal Circuit, “Generic use of AI without other parameters, such as “improving the mathematical algorithm or making machine learning better,” is abstract.”
Said the court,
The use of case information in the claimed database simply involves the use of AI as applied to a new environment and cannot render the claims non abstract…. Nor does the database otherwise involve a nonabstract concept. Our cases suggest that adding new content to a database is insufficient to render claims directed to a database non-abstract.
Also, “The use of a data structure that is “already routine and conventional” will not render a claim non-abstract.”
Rensselaer also argued that “it is undisputed that case-based reasoning did not exist anywhere within the NLP field before the [’798] Patent.”
The court noted that these arguments “speak to novelty, which is a separate inquiry.”
The court concluded:
A conventional application of case-based reasoning, even to a novel environment, is abstract. Therefore, the application of case-based reasoning to natural language processing does not provide an inventive concept sufficient to render the claims patent-eligible…
The court thus held that the claims of the ’798 patent are directed to ineligible subject matter under § 101.
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