SnowCast Solutions LLC v. Endurance Speciality Holdings, LTD.

SnowCast Solutions LLC v. Endurance Speciality Holdings, LTD., C.A. 15-cv-5305 (N.D. Ill. March 23, 2016).

Patent(s):    

  • 8,543,427 | Entitled “Weather risk management system”
  • 8,924,242 | Entitled “Weather risk management system”

Disposition:               

Rule 12(b)(6) Motion to Dismiss granted. 

Abstract Idea:

Yes

Something More:

No

Technology:              

Method of pricing and hedging weather derivatives. 

Summary:                 

Judge Manish Shah granted the defendant’s motion to dismiss on the grounds that claims were nothing more than a computer implemented method for risk and cost management of weather related services. As a threshold matter, the concept of hedging or protecting against risk, even for weather related services, was still an abstract idea. Additionally, there was nothing particularly inventive about the method sufficient to transform the abstract idea into a patent-eligible application. The system merely took data entered by the user, linked to an existing database, and applied an algorithm to calculate numbers. Further, rote statements of generic computer components did not satisfy the inventive concept requirement.