The board has recently constricted its interpretation of the covered business method requirement in instituting CBM reviews. In a decision on a another petition for CBM review, the board similarly rejected an argument that a patent directed to the management of regulatory changes for business activities was related to the practice, administration, or management of a financial product or service. See Salesforce.com, Inc. v. Applications in Internet Time, LLC, CBM201400168 (PTAB Feb. 2, 2015).
J.P Morgan Chase v. Intellectual Ventures II LLC, CBM201400160 (PTAB Jan. 29, 2015).
