Capital Dynamics v. Cambridge Associates, LLC

Capital Dynamics v. Cambridge Associates, LLC, No. 2016-1318 (Fed. Cir. Sep. 9, 2016) 

Patent(s):

  • 7,698,196 | Entitled “Method and system for modeling and benchmarking private equity and applications of same”

Disposition:               

Affirmance of final written decision.

Abstract Idea:

Yes

Something More:

No

Technology:              

Method for benchmarking relative to an index a performance of a financial product having an irregular cash flow.

Summary:                 

The decision of the Board was affirmed per curiam. The Federal Circuit agreed with the Patent Trial and Appeal Board that the claims are unpatentable under 35 U.S.C. § 101. The Board found that the claims in dispute were directed to the abstract idea of a mathematical correlation, citing the specification. The mathematical functions and sources of data involved were already known in the art. The Board found that there was no inventive concept, finding effectively harmless error in the petitioner's expert’s demonstration of prior art calculations.