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21的鼓 0站台

Intellectual Ventures v. Capital One (Fed. Cir. March 7, 2017)

U.S. Patent No. 7,984,081

21. An apparatus for manipulating XML documents, comprising:

a processor;

a component that organizes data components of one or more XML documents into data objects;

a component that identifies a plurality of primary record types for the XML documents;

a component that maps the data components of each data object to one of the plurality of primary record types;

a component that organizes the instances of the plurality of primary record types into a hierarchy to form a management record type;

a component that defines a dynamic document for display of an instance of a management record type through a user interface; and

a component that detects modification of the data in the dynamic document via the user interface, and in response thereto modifies a data component in an XML document.

本案abstract idea概疑

主要的重在於：

(1) interface法abstract idea具可利性

“the patent accomplishes this by creating a “dynamic document” based upon the MRTs and PRTs, so the system can modify multiple sets of XML data components at once through a user interface.”

生“dynamic document”做interface是否可abstract idea具可利性

CAF：

And the recited dynamic document provide little more than an unspecified set of rules for displaying and organizing MRTs in a user interface akin to the generic interfaces we have elsewhere explained impart no inventive concept. See, e.g., Intellectual Ventures I, 792 F.3d at 1370 (finding that the recited “interactive interface” was not a “specific application of the abstract idea that provides an inventive concept”); Affinity, 838 F.3d at 1262 (characterizing a “graphical user interface” as a “generic feature” of the invention).

(2)有解的技特徵就有可利性

Although the claims purport to modify the underlying XML document in response to modifications made in the dynamic document, this merely reiterates the patent’s stated goal itself. Nothing in the claims indicate what steps are undertaken to overcome the stated incompatibility problems with XML documents to propagate those modifications into the XML document. Indeed, the claim language here provides only a result oriented solution, with insufficient detail for how a computer accomplishes it.

然藉由"modification”可以解XML文件相容性的

但是claim中看不出"modification”的技特徵