The U.S. Court of Appeals for the Federal Circuit (CAFC) has reversed a lower court's decision in BerkeleyIEOR v. W.W. Grainger Inc.*, holding that the asserted profitability-calculation patent claims are ineligible under Section 101. The district court had previously granted summary judgment in favor of the patent owner, but the CAFC disagreed, finding the claims directed to an abstract idea without an inventive concept.
The ruling continues the Federal Circuit's trend of applying the Alice two-step test strictly, particularly for software patents that automate routine economic calculations. The court emphasized that the claims did not improve computer functionality or solve a technical problem, but rather merely implemented a known financial concept on a generic computer.
This decision serves as a cautionary note for patent applicants and litigants in the financial technology space: claims that focus on profitability calculations, even if technically detailed, must demonstrate a technological improvement to survive Section 101 scrutiny. The case will now return to the district court for further proceedings consistent with the CAFC's opinion.