Versata Development Group, Inc. v. SAP America, Inc.

793 F.3d 1306, 115 U.S.P.Q.2d 1681 (2015)

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Versata Development Group, Inc. v. SAP America, Inc.

United States Court of Appeals for the Federal Circuit
793 F.3d 1306, 115 U.S.P.Q.2d 1681 (2015)

Facts

Versata Development Group, Inc. (Versata) (plaintiff) plaintiff held a patent on a method and apparatus for pricing products in organizational tables. Versata brought an infringement action against SAP America, Inc. (SAP) (defendant) in federal district court. SAP requested that the United States Patent and Trademark Office (PTO) review the patent’s validity pursuant to § 18 of the Leahy-Smith America Invents Act, a transitional program providing for post-grant review of the validity of patents directed to business methods. Section 18 defined a covered business method as a method or apparatus used in the practice or management of a financial product or service. Technological inventions were excluded from the definition. The PTO’s Patent Trial and Appeal Board (the board) determined that Versata’s patent claimed an invention that qualified as a covered business method under § 18 and that several of the patent’s claims were invalid. Versata appealed to the United States Court of Appeals for the Federal Circuit, arguing that the invention was not a § 18 covered business method. The PTO countered that the decision of what constituted a covered business method was strictly a matter of the board’s authority and not open to appellate review.

Rule of Law

Issue

Holding and Reasoning (Plager, J.)

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