Cybersource Corp. v. Retail Decisions, Inc., No. 09-1358 (Fed. Cir. 2011)Annotate this Case
Plaintiff's patent recites a method for detecting fraud in a credit card transaction over the Internet; the specification explains that prior systems, which generally rely on billing addresses and personal identification information, work well for face-to-face transactions and transactions where the merchant ships a package. For online sales where the product is downloadable, address and identity information do not verify that the purchaser is actually the credit card owner. The patent purports to solve this problem by determining whether an Internet address relating to a transaction is consistent with other Internet addresses that have been used with the same credit card. The district court granted summary judgment of invalidity under 35 U.S.C. 101 for failure to recite patent-eligible subject matter. The Federal Circuit affirmed, holding that the disputed claims attempt to capture unpatentable abstract ideas. One could mentally perform the fraud detection method that underlies the patent, as the method consists of only the general approach of obtaining information about credit card transactions utilizing an Internet address and then using that information in some undefined manner to determine if the credit card transaction is valid.