RFC Lenders of Texas v. Smart Chemical Solutions: Functional Claims Directed to Monitoring Vehicles for Unauthorized Usage Fail to Recite Patentable Subject Matter

In today’s RFC Lenders of Texas v. Smart Chemical Solutions case (nonprecedential), the Federal Circuit needed very little analysis to affirm a district court’s grant of a motion to dismiss, finding the claims ineligible under 35 U.S.C. § 101. The technology involves monitoring vehicles for unauthorized usage. The claims were functionally drafted (e.g., “detecting movement or activation of the vehicle,” “transmitting a signal indicating movement or activation of the vehicle, to a control center,” etc.).

At Alice’s step one, the court simply agreed with the district court’s conclusion that the claims are “directed to the basic concept of monitoring vehicles and lacking any ‘concrete or tangible form.'” The court explained that the claims “invoke only generic computer functions … in result-oriented language without providing specifics as to how to achieve the claimed results.” The court provided an example, “the step of ‘detecting at the vehicle the presence of a landmark’ lacks any meaningful detail regarding how to do so in a nonconventional way.” The court therefore concluded that the claim is directed to “an abstract idea that merely invokes computers as tools.” Interestingly, after determining what the claim at issue is directed to, the Federal Circuit usually compares that to its prior cases to determine if that subject matter has been determined to be an abstract idea before. Here, apparently, the claim was so obviously directed to an abstract idea that it did not feel the need to do so.

At step two, the court had an easy time because the patent specification made clear that “the claimed steps are themselves conventional, well-understood, and routine, and any of the generic computer components invoked therein would only operate according to their ordinary functions to carry out the claimed functions.”

There are no big takeaways here other than to note that this is yet another in a long string of cases where the Federal Circuit is finding result-oriented claims patent ineligible.