In another district court decision applying Bilski v. Kappos, the U.S. District Court for the District of Columbia has declared four patents invalid as directed to unpatentable “abstract ideas.” CLS Bank Int’l v. Alice Corp. Pty. Ltd., No. 07-974, 2011 WL 80207, at *1 (D.D.C. Mar. 9, 2011). The decision addresses patents purporting to cover computer-implemented methods, systems, and products for exchanging financial obligations. If this decision is upheld on appeal, it could have sweeping effects on business and financial method patents, calling into question the validity of these types of patents across many technology sectors.

Patentee Alice Corporation claimed that CLS Bank infringed four patents directed to methods, systems, and computer-program products for employing a computerized intermediary to facilitate the simultaneous exchange of obligations in order to minimize risk. Essentially, Alice’s patents claim computer systems and technology used across the world’s financial system to settle foreign exchange transactions. CLS Bank asserted in response that Alice’s business and financial method patents were invalid as directed to non-statutory subject matter and moved for summary judgment. Judge Rosemary M. Collyer of the D.C. District Court agreed, and held Alice’s patents invalid. The court found that the basic business or financial concept of settling financial obligations via a computer system unpatentable, and compared Alice’s patents to the hedging method struck down by the U.S. Supreme Court in Bilski. See id. at *21–22 (citing Bilski v. Kappos, 130 S. Ct. 3218 (2010)).