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Improvements To Other Technology Or a Technical Field
Under this category, courts have also found that improvements in technology beyond computer functionality may demonstrate patent-eligibility. In one case (mentioned above), the Federal Circuit held claimed methods of automatic lip synchronization and facial expression animation using computer-implemented rules to be patent-eligible because the claims were directed to an improvement in computer animation technology. The court relied on the specification’s explanation of how the claimed rules enabled the automation of specific animation tasks that previously could not be automated. The court indicated that it was the incorporation of the particular claimed rules in computer animation that improved the existing technological process, unlike cases such as Alice where a computer was merely used as a tool to perform an existing process. The court also noted that the claims at issue described a specific way (use of particular rules to set morph weights and transitions through phonemes) to solve the problem of producing accurate and realistic lip synchronization and facial expressions in animated characters, rather than merely claiming the idea of a solution or outcome, and thus were not directed to an abstract idea.
However, it is important to keep in mind that an improvement in the abstract idea itself (e.g. a recited fundamental economic concept) is not an improvement in technology. For example, one court determined that the claimed user interface simply provided a trader with more information to facilitate market trades, which improved the business process of market trading but did not improve computers or technology.
The following are some examples relevant to FinTech (and potentially related technologies) that the courts have indicated may be sufficient to show an improvement in existing technology:
• An advance in the process of downloading content for streaming;
• Improved, particular method of digital data compression;
• Particular method of incorporating virus screening into the Internet;
• Components or methods, such as measurement devices or techniques, that generate new data;
• Particularconfigurationofinertialsensorsandaparticular method of using the raw data from the sensors; and
• A specific, structured graphical user interface that improves the accuracy of trader transactions by displaying bid and asked prices in a particular manner that prevents order entry at a changed price.
To show that the involvement of a computer assists in improving the technology, the claims must recite the details regarding how a computer aids the method, the extent to which the computer aids the method, or the significance of a computer to the performance of the method. Merely adding generic computer components to perform the method is not sufficient. Thus, the claim must include more than mere instructions to perform the method on a generic component or machinery to qualify as an improvement to an existing technology.
The following are some examples where courts have indicated the claim may not be sufficient to show an improvement to technology:
• A commonplace business method being applied on a general purpose computer;
• Gathering and analyzing information using conventional techniques and displaying the result;
• A general method of screening emails on a generic computer; and
• An advance in the informational content of a download for streaming
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Key Insights for Obtaining FinTech Patents