Versata Development Group, Inc. v. SAP America, Inc.
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Versata Development Group, Inc. v. SAP America, Inc., 793 F.3d 1306 (Fed. Cir. 2015),[1] is a July 2015 decision of the Federal Circuit affirming the final order of the Patent Trial and Appeal Board (PTAB), the recently created adjudicatory arm of the United States Patent and Trademark Office (USPTO), invalidating as patent ineligible the claims in issue of Versata's U.S. Patent No. 6,553,350[2] (the '350 patent). This was the first case in the Federal Circuit reviewing a final order in a Covered Business Method (CBM) invalidation proceeding under the America Invents Act (AIA).[3] The case set an important precedent by deciding several unsettled issues in the interpretation of the CBM provisions of the AIA>,[4] including what are business-method patents under the AIA and whether the AIA authorizes the PTO to hold such patents invalid in CBM proceedings on the ground that they are patent ineligible under 35 U.S.C. § 101 as "abstract ideas."
Versata Dev. Group, Inc. v. SAP Am., Inc. | |
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Court | United States Court of Appeals for the Federal Circuit |
Full case name | Versata Development Group, Inc. v. Sap America, Inc., Sap Ag, Under Secretary Of Commerce For Intellectual Property, Director Of The United States Patent And Trademark Office, Intervenor |
Decided | July 9 2015 |
Citations | 793 F.3d 1306; 2015 U.S. App. LEXIS 11802; 115 U.S.P.Q.2d 1681 |
Holding | |
(1) The Federal Circuit may review issues decided by the Patent Trial and Appeal Board (PTAB) to determine the ultimate merits; (2) the invention claimed was a covered business method patent under § 18; (3) the PTAB's claim constructions were affirmed; (4) 35 U.S.C. § 101 applied in a § 18 review; and (5) the patent claims at issue were properly held invalid under § 101. | |
Laws applied | |
Pub. L. No. 112-29, § 18, 125 Stat. 284, 329-331 (2011) |