Google, Inc. v. Patrick Zuili

Google, Inc. v. Patrick Zuili, CBM2016-00021, May 5, 2017 (James Lee, Glenn J. Perry, and Miriam L. Quinn)  


  • 7,953,667 | Entitled, “Method and System to Detect Invalid and Fraudulent Impressions and Clicks in Web-Based Advertisement Systems”


PTAB found claims 1–3, 6, 10, 14, 15, 18, 19, and 21 to be patentable. 

Abstract Idea:


Something More:



Monitoring consumer activity on websites to prevent pay-per-click fraud.


PTAB found that “the challenged claims are directed to the abstract idea of “detecting fraud based on the time between two requests by the same client.” The PTAB further found that the claims were merely directed at using generic process and machinery to carry out this idea. The claims and specification merely described using ordinary computers and routine code to compare the time between clicks. 

Noting that the claims simply implementing data collection and processing, the PTAB found that the claims were invalid because they were merely an abstract idea without an inventive step. In closing the court noted that “[t]he key to the claimed solution here lies in recording who is making a request and measuring the duration between two requests from the same source, using conventional and generic processes and machinery. That is insufficient to render the claimed invention patent eligible.