Priceplay.com, Inc. v. AOL Advertising, Inc., et al.

Priceplay.com, Inc. v. AOL Advertising, Inc., et al., Nos. 2015-1492, 2015-1589, 2016-1660 (Moore, Bryson, Wallach, J.) (Fed. Cir. Jan. 7, 2016)

Patent(s):

  • 8,050,982 | Entitled, “Systems and methods for transacting business over a global communications network such as the internet”
  • 8,494,917 | Entitled, “Systems and methods for transacting business over a global communications network such as the internet”

Disposition:

Affirmed dismissal under § 101 per curiam

Abstract Idea:

Yes

Something More:

No

Technology:

Business process for conducting transactions over the Internet, allowing buyers to reduce the price of a product or service based on buyer’s performance during a “price determining activity.”

Summary:

The Federal Circuit issued a per curiam opinion where it affirmed the district court’s dismissal under Rule 12(b)(6).  The district court noted that the claims were directed to the abstract idea of a sales transaction which is a fundamental economic concept, which is akin to “intermediate settlement” and “risk hedging” as found in Alice and Bilski, respectively.  From there the district court determined that there was no inventive concept as the addition of an auction and competitive activity to a sales transaction is nothing more than the addition of “well-understood, routine, conventional activity,” and the addition of the Internet “does not save the claimed invention from invalidity.”