Apple, Inc. v. Ameranth, Inc, et al. 15-7503 (Fed. Cir. Nov. 29, 2016)
- 6,384,850 | Entitled information management and synchronous communications system with menu generation
- 6,871,325 | Entitled information management and synchronous communications system with menu generation
- 6,982,733 | Entitled information management and synchronous communications system with menu generation, and handwriting and voice modification of orders
Affirmance-in-part and reversal-in-part of CBM final decision
Methods and systems of generating computer menus
As to the claims the PTAB had invalidated, the court found no fault in the PTAB’s change in description of the abstract idea from generating a menu at institution to generating a second menu from a first menu and sending the second menu to another location at final decision. This change did not impact the patentability analysis. The court affirmed the PTAB’s finding and agreed the patent claims are directed to functionality only - the ability to generate menus. The court rejected the appellant’s contention that the difficulty of the limitations is relevant to inventiveness, and pointed to the specification for concessions that the limitations were directed to ordinary implementation techniques.
As to certain dependent claims the PTAB had found not invalid, the court again turned to the specification to find that the purported inventive techniques were already known and found no disclosure of the technological implementation there. The court also relied on concession at oral argument that in the prior art, restaurants were able to track customers’ orders. As to other dependent claims the PTAB had found not invalid, the court reversed the district court’s finding that the use of handwriting and voice capture techniques were inventive, as there was no description of how these would be inventive, and these techniques themselves were not inventive and already known. In so concluding, the court found all claims of all asserted patents invalid.