## Facts

- Internet Patents Corp. owned U.S. Patent No. 7,707,505, directed to retaining user-entered data in online forms when a user navigates away and returns using a browser’s Back/Forward controls.
- The patent described an “intelligent user interface” that maintains the “state” of form fields during ordinary web navigation to prevent data loss.
- Internet Patents sued Active Network, Inc. and others for infringement in consolidated actions.
- After *Alice*, defendants moved to dismiss under Federal Rule of Civil Procedure 12(b)(6), arguing the asserted claims were invalid under 35 U.S.C. § 101.
- The district court granted the motion, concluding the claims were directed to an abstract idea and contained no additional inventive features beyond generic computer implementation.
- Internet Patents appealed.

## Issues

1. Whether the asserted claims are directed to an abstract idea under 35 U.S.C. § 101 (Alice step one).
2. If so, whether the claims include an inventive concept that transforms the abstract idea into patent-eligible subject matter (Alice step two).
3. Whether patent ineligibility under § 101 may be resolved on a Rule 12(b)(6) motion based on the patent and pleadings.

## Decision

- The Federal Circuit affirmed the district court’s Rule 12(b)(6) dismissal.
- The court held the claims were directed to the abstract idea of retaining information in the navigation of online forms.
- The court held the claims lacked an inventive concept because they added only generic computer, network, and browser components and result-oriented functional language.

## Legal Principles

- Under the *Mayo/Alice* framework, courts (1) determine whether claims are directed to an abstract idea and, if so, (2) assess whether additional claim elements, individually and as an ordered combination, supply an inventive concept.
- Claims that recite a desired result (e.g., “maintaining state” or “retaining information”) without specifying a particular technical means for achieving it are likely abstract and ineligible.
- Adding conventional Internet and computer components (e.g., user computer, network, web page/host server, standard browser controls) does not supply an inventive concept when those components merely implement the abstract idea.
- Patent eligibility may be decided at the pleading stage when ineligibility is evident from the claims and patent disclosures, making the issue a matter of law on the available record.

## Conclusion

The Federal Circuit held that claims directed to preserving online-form data during ordinary browser navigation were patent-ineligible because they claimed a functional result at a high level of generality and relied on generic computer implementation without reciting a specific technical method that would transform the abstract idea into a patent-eligible application.


Internet Patents Corp. v. Active Network, Inc., 790 F.3d 1343 (Fed. Cir. 2015)