Internet Patents Corp. v. Active Network, Inc., No. 14-1048 (Fed. Cir. 2015)Annotate this Case
The 505 Patent claims “the use of a conventional web browser Back and Forward navigational functionalities without data loss in an online application consisting of dynamically generated web pages,” “retaining information lost in the navigation of online forms.” The district court rejected an infringement suit, deeming this to be an abstract concept, ineligible for patenting, 35 U.S.C. 101. While appeal was pending, the Supreme Court decided Alice Corp. v. CLS Bank International. The Federal Circuit affirmed, stating that by setting out the abstract idea of a known technological challenge without setting out any specific disclosures, the Patent “added no elements or combination of elements, sometimes referred to as the inventive concept, sufficient to ensure that the patent in practice amounts to significantly more than a patent upon the natural law or the abstract idea.