District Court Holds “Hypothesis Testing” Patents Invalid Under Alice

Feb 4, 2015

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The district court found that the “method of applying hypothesis testing to a data set” in each of the patents at issue was an abstract concept, analogizing it to the patent­ineligible mathematical calculations and business processes in Parker v. Flook, 437 U.S. 584 (1978) and Bilski v. Kappos, 561 U.S. 593 (2010). The court then found that the claim language merely recited “well­known, conventional activities” such as obtaining information from a user, selecting an appropriate test to apply to a data set, applying the test, interpreting the results, and displaying a summary of the results. These activities were not sufficiently inventive to make the patent claim more than a broad claim to the concept of automatic hypothesis testing.

Minitab, Inc. v. EngineRoom, LLC, No. 4:12­cv­2170 (M.D. Pa. Feb. 3, 2015).

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