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Internet Patents Corp. v. Active Network, Inc.

790 F.3d 1343, 115 U.S.P.Q.2d 1414 (2015)

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Internet Patents Corp. v. Active Network, Inc.

United States Court of Appeals for the Federal Circuit
790 F.3d 1343, 115 U.S.P.Q.2d 1414 (2015)

Facts

Internet Patents Corporation (IPC) (plaintiff) held a patent on the ability of a web user to navigate back and forward on a browser without a loss of data (e.g., information entered into online forms). IPC brought an infringement action against The General Automobile Insurance Services, Inc. (defendant); Active Network, Inc. (defendant); Tree.com, Inc. (defendant); and Quin-Street, Inc. (defendant). The federal district court held that the patent was invalid because back and forward navigational functionality was an abstract concept lacking the elements or combination of elements that would be necessary to qualify it as a patent-eligible invention. IPC appealed to the United States Court of Appeals for the Federal Circuit, emphasizing the claimed invention’s retention of data as the key innovation over the prior art.

Rule of Law

Issue

Holding and Reasoning (Newman, J.)

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