Predictive Analytics Patent Claims Invalid Under 35 U.S.C. § 101
The court granted defendant’s motion to dismiss because the asserted claims of plaintiff’s predictive analytics patent encompassed unpatentable subject matter and found that the claims were directed toward an abstract idea. “[Plaintiff’s] claims are directed to a mental process and the abstract concept of using mathematical algorithms to perform predictive analytics. The method of the predictive analytics factory is directed towards collecting and analyzing information. The first step, generating learned functions or regressions from data — the basic mathematical process of, for example, regression modeling, or running data through an algorithm — is not a patentable concept. . . . While [plaintiff] claims that this shows it would be impossible for a human to perform such a task, just because a computer can make calculations more quickly than a human does not render a method patent eligible. . . . [Plaintiff] fails to identify any previously existing technology that its claims improve upon, or that its claims do more than carry out regression analysis and evaluation.”
Purepredictive, Inc. v. H2O.AI, Inc., 3-17-cv-03049 (CAND August 29, 2017, Order) (Orrick, USDJ)
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