Friday, February 26, 2021
In
cxLoyalty, Inc. v. Maritz Holdings Inc., Nos. 2020-1307, 1309 (February 8, 2021), the Federal Circuit found both original and substitute claims in a covered business method review ineligible for patent protection under 35 U.S.C. § 101.
cxLoyalty filed a petition for covered business method review, challenging claims 1–15 of U.S. Patent No. 7,134,087, owned by Maritz. The ’087 patent claimed a system and method that automates the process of redeeming credit card loyalty points for rewards. Instead of requiring human participation, as in traditional systems, the ’087’s system uses computer-based interfaces to streamline the process.
The Board found all challenged claims were patent ineligible because they related to an abstract idea under 35 U.S.C. § 101. But the Board found no such issue with Maritz’s substitute claims, 16–23, deeming them patent-eligible. cxLoyalty appealed the Board’s ruling on the substitute claims; Maritz cross-appealed the Board’s ruling on the original claims and the Board’s institution of CBM review.