Aatrix Software, Inc v. Green Shades Software, Inc, No. 17-1452 (Fed. Cir. 2018)
Annotate this CaseAatrix's patents have essentially the same specification and are directed to systems and methods for designing, creating, and importing data into a viewable form on a computer so that a user can manipulate the data and create viewable forms and reports. The preferred embodiment describes a data processing system with a form file, a data file, and a viewer. The form file is created using in-house form development tools to model the physical characteristics of an existing form, including the calculations and rule conditions required to fill in the form. The data file allows data from third-party applications to be “seamlessly imported” to populate the form's fields. The viewer generates a report by merging the data, performing calculations, and allowing the user to review and change the values. In an infringement action, the district court found several claims invalid as directed to ineligible subject matter under 35 U.S.C. 101. The Federal Circuit vacated the dismissal. . The district court erred in determining that a claim was ineligible because it is not directed to a tangible embodiment and in denying leave to amend without claim construction. The court noted factual allegations in a proposed amended complaint, that, if accepted, establish that the claimed combination contains inventive components and improves the workings of the computer.
The court issued a subsequent related opinion or order on May 31, 2018.
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