CAFC Rules Against PersonalWeb

The Court of Appeals for the Federal District has issued a precedential decision that PersonalWeb Technologies’ patent claims against Google, Facebook, EMC Corporation and VMware, Inc are ineligible under Section 101. PersonalWeb argued that the patent covers “a substantially unique, algorithm-derived, content-based identifier for all data items in a networked computer, which allows a computer within a network containing diverse computing and storage systems to locate and distribute data without knowing either the file system of any device within the network or the conventional name of any data item.” The CAFC adopted the Northern District of California’s analysis when it ruled against PersonalWeb, and said that the functions claimed are representative of “mental processes that ‘can be performed in the human mind’ or ‘using a pencil and paper.’” It cited Google and Facebook’s example of librarians, who “often locate books based on a ‘call system’ where they assign books unique identifiers based on call numbers, which change dependent on a book’s volume, etc.” to locate books. According to the CAFC, although PersonalWeb performs the task in a computer environment, “that doesn’t transfigure an idea out of the realm of abstraction.”