Dear Judge Williams: Pursuant to the Court’s May 16, 2024 Order (D.I. 24), Defendants identify Alice Corp. v.CLS Bank Int’l, 573 U.S. 208 (2014) and Personal Web Tech. LLC v. Google LLC, 8 F.4th 1310(Fed. Cir. 2021) as analogous and decisive here.As in Alice, the asserted patent is directed to processing financial transactions. Aliceinstructs that claims relating to “exchanging financial obligations between two parties” riskpatenting a “fundamental economic practice”—which is “squarely within the realm of abstractideas.” 573 U.S. at 219-221. Alice makes clear that such claims must amount to “significantlymore” than “electronic recordkeeping” using “conventional” computer tools. Id. at 225. “Nor islimiting use of the claims to a particular technological environment” enough to survive § 101. Id.at 223. Here, the claims are a textbook example of a “fundamental economic practice” limited toa “particular technological environment”—blockchain. The first part of the claims recitesconventional computer components—“server,” “network,” “document store,” and “message bus.”D.I. 1-1, 62:1-12. The second part of the claims uses technical jargon to recite basic functions ofelectronic recordkeeping—generating a record using information from the transaction (“enricheddata record”), tracking the information using an identifier (“token”), and storing this informationon a ledger (generic “blockchain”). Id., 62:13-25. This technical jargon cannot mask the fact thatthe claims merely recite “well-understood, routine, conventional activities.” 573 U.S. at 225.This case is also analogous to Personal Web, where the Federal Circuit invalidated claimsreciting a “content-based identifier” like the claimed “token” here. At step 1, the court held that“using a content-based identifier” to “retriev[e] data” is “an abstract data-management function”—like a library “call system where they assign books unique identifiers based on call numbers.” 8F.4th at 1316-18. The claims here are drawn to the same abstract idea: “generat[ing] [] a tokencorresponding to the financial transaction” and using the token to “identify ... documents.” D.I.1-1, 62:13-25. Further, like the claimed “token” here, the court held that “[g]enerating suchidentifiers via a known algorithm is no less abstract.” Id. At step 2, the court asked “what else isthere in the claims before us?” and answered “not much.” Id. at 1319. The same question andanswer apply here. The claims merely recite conventional tools to perform data managementfunctions: “server,” “network,” “document store,” and “message bus.” The asserted patent alsomakes clear that the claimed “blockchain” is generic, stating that “any blockchain basedframework” can be used. D.I. 1-1, 24:21-23; Rady v. Boston Consul., 2024 WL 1298742, *4-5(Fed. Cir. 2024) (affirming patent ineligibility when “claimed invention relies on the conventionaluse of existing blockchain technology” and “recording a particular type of information ... to ablockchain does not mean that it improves the underlying blockchain technology”).
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