Smart Software, Inc. v. Planningedge

Smart Software, Inc. v. Planningedge, LLC, No. CV 15-13814-PBS, 2016 WL 3390691, at *5 (D. Mass. June 17, 2016)


6,205,431 | Entitled, “System and Method for Forecasting Intermittent Demand”


Motion to Dismiss on the grounds of invalidity allowed

Abstract Idea:


Something More:



The patented technology includes an inventory management system that utilizes the theory of economic order quantities under a continuous review model. The review model determines two quantities for each item, a reorder point and an order quantity using historical data. When on-hand inventory reaches the reorder point, one orders an amount equal to the order quantity to replenish stock.


The court concluded at step one of the Alice test that the '431 Patent claims were directed to patent ineligible subject matter because the patent’s claimed function of forecasting intermittent demand was an abstract idea similar to risk hedging. At step two, the '431 Patent did not provide something more that made the subject matter patent eligible because it merely described a generic computer system to carry out the entire process.