Data Engine Techs v. Google (Fed. Cir. 2021)
This is an old-school affirmation architecture case. The commune cloister almost construed DET’s affirmation appellation “three-dimensional spreadsheet” and appropriately disqualified that Google does not infringe. On appeal, the Federal Circuit has affirmed.
DET’s apparatus actuality is mainly about abacus tabs to a spreadsheet to accomplish it “three dimensional.” In a above-mentioned decision, the Federal Circuit begin the claims patent-eligible. “[T]he affirmation is directed to a specific adjustment for abyssal through three-dimensional cyberbanking spreadsheets. . . . The Tab Patents apparent [a] accepted abstruse botheration in computers in a accurate way—by accouterment a awful intuitive, convenient interface with accustomed anthology tabs for abyssal the three-dimensional worksheet environment.”
Judge Stark had construed the claims above-mentioned to his accommodation ruling. On remand, however, Google asked for added affirmation architecture of the conference appellation “three-dimensional spreadsheet” aback that aspect of the apparatus had been analytical to the Federal Circuit’s accommodation determination.
The commune cloister did analyze the appellation in a attenuated appearance — acute “a algebraic affiliation amid beef on altered spreadsheet pages.” This architecture about requires anniversary tab to be a band in a assemblage of bedding and that the adjustment of the bedding accept algebraic importance. In the archetype aloft the “Salads” band is one-page abroad from “Entrees”, and two pages from “Desserts.” A algebraic accord is all-important to acquiesce for 3-D appearance such as 3-D ranges. The blueprint explains that
Three-dimensional spreadsheets acquiesce the user to actualize a worksheet having beef abiding in a 3-D grid. In this manner, the user can dispense multi-dimensional ranges, i.e., Solid blocks of cells. This affection has audible advantages. For example, the user can anatomy a worksheet consisting of assorted two dimensional spreads, ascertain 3-D ranges that amount these spreads, and archetype a ambit of rows and columns into anniversary of abounding 2-D spreads at once. This affection eases difficult choirs, such as alliance of assorted spreads.
‘259 Patent at Col. 2-3. Further, in the case history, the patentee acclaimed a Lotus-123 above-mentioned art advertence acceptance bond amid altered pages as not apery a “true 3D spreadsheet.”
One affair actuality is that the 3D spreadsheet affirmation is allotment of the conference of the claim, not the anatomy of the claim.
12. [A] computer-implemented adjustment of apery a three-dimensional spreadsheet on a awning display, the adjustment absolute . . .
Ordinarily, preambles are not limiting. Here, the Federal Circuit admitting fell aback on the nose-of-wax affinity — answer that the patentee had already pushed the wax in one administration and is now estopped from blame it back. Namely, during the accommodation determination, the patentee pushed its case as an advance to three-dimensional spreadsheets, and the cloister relied aloft those arguments to acquisition the apparatus acceptable for patenting.
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