The collection, analysis, and display of information does not generally amount to significantly more under Mayo/Alice step two. Here, for example, the real-time performance monitoring of an electric power grid was found to be patent-ineligible because the claims simply recited a reorganization of information that was already known. “[M]erely selecting information, by content or source, for collection, analysis, and display does nothing significant to differentiate a process from ordinary mental processes, whose implicit exclusion from § 101 undergirds the information-based category of abstract ideas.” It may therefore be best to avoid purely information-based claiming.
Background / Facts: The patent being asserted here is directed to real-time performance monitoring of an electric power grid by collecting data from multiple data sources, analyzing the data, and displaying the results.
Issue(s): Whether the claims are patent-eligible under 35 U.S.C. § 101.
Holding(s): No. After quickly concluding that the “claims are clearly focused on … abstract-idea processes,” the court found that “a large portion of the lengthy claims is devoted to enumerating types of information and information sources available within the power-grid environment. But merely selecting information, by content or source, for collection, analysis, and display does nothing significant to differentiate a process from ordinary mental processes, whose implicit exclusion from § 101 undergirds the information-based category of abstract ideas. The claims in this case do not even require a new source or type of information, or new techniques for analyzing it.”