Priceplay.com, Inc. v. AOL Advertising, Inc., C.A. No. 14 – 092 – RGA, March 18, 2015.

Andrews, J.  Defendant’s motion to dismiss for failure to state a claim is granted as to all claims in the two patents-in-suit.

The disputed technology relates to a business process for conducting business sales transactions over the internet.  In applying the Alice framework, the court finds that the claims of the two patents are drawn to patent-ineligible subject matter.  No inventive concept is involved.  A sales transaction is a fundamental economic practice in commerce, and performing it over the internet does not make it more concrete.  No inventive concept is provided by the addition of an auction and competitive activity, well-understood, routine, conventional activities.  The patents are invalid under section 101.