Once Again, the Purpose of the Invention Determines Patent-Eligibility

In ruling on a motion for judgment on the pleadings, the Northern District of Ohio recently determined that a patent for searching and unifying data was invalid for lack of patentable subject matter. See DATATRAK International, Inc. v. Medidata Solutions, Inc., 1-11-cv-00458 (N.D. Ohio Nov. 6, 2015 Order). Of particular note, the court stated that the problems the patent at issue purportedly solved – “data overload,” “costs for organizing data,” “data permissions,” and “downstream proliferation of data” – were not necessarily rooted in computer technology as those same problems affect noncomputerized data storage as well. This case fits into a broader trend where courts analyze the purpose of the invention to determine whether it complies with § 101.

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