In the non-precedential decision Planet Bingo, LLC v. VKGS, LLC, the Federal Circuit applied the analysis handed down in the Supreme Court’s recent decision of Alice Corp. v. CLS Bank International in determining that the claims at issue lack an inventive concept sufficient to transform the claimed subject matter into a patent-eligible application.
Noting that there was no meaningful distinction between the method and system claims at issue, the Court set about identifying the idea encompassed within the claims.
“Generally, the claims recite storing a player’s preferred sets of bingo numbers; retrieving one such set upon demand, and playing that set; while simultaneously tracking the player’s sets, tracking player payments, and verifying winning numbers,” the Court said. Such management, the Court reasoned, consists solely of mental steps that can be carried out by a human using pen and paper.
Of further note was the Court’s determination that the claims recite a generic computer implementation of the covered abstract idea. Thus, the Court further reasoned, the steps performed are purely conventional.