Westlake Services, LLC v. Credit Acceptance Corp.

Westlake Services, LLC v. Credit Acceptance Corp., CBM2014-00176 (McKone, APJ.) (Jan. 25, 2016)


6,950,807 | Entitled “System and method for providing financing”


Final written decision invalidating claims

Abstract Idea:


Something More:



Method providing financing for a customer to purchase a product selected from an inventory of products maintained by a dealer.


In its final written decision, the court found that processing an application for financing a purchase is a method of organizing human activity, or the performance of an abstract business practice. Claims were similar to those found invalid in DealerTrack, Inc. v. Huber, 674 F.3d 1315 (Fed. Cir. 2012) and Mortgage Grader, Inc. v. First Choice Loan Services, 2015-1415 (Fed. Cir. Jan. 20, 2015). Court rejected arguments of novelty of purported invention as irrelevant for Section 101 analysis. Generic computing limitations such as “database” and “data storage unit” did not add inventive concept.