HANTZ SOFTWARE, LLC, V SAGE INTACCT, INC., FEDERAL CIRCUIT 2023 (SOFTWARE PATENTS)

Any ineligibility judgment should apply to only claims asserted in a complaint if held patent-ineligible after a motion to dismiss for failure to state a claim.

Hantz sued Sage alleging that Sage infringed U.S. Patent Nos. 8,055,559 and 8,055,560. Sage moved to dismiss the complaint for failure to state a claim under Federal Rule of Civil Procedure 12(b)(6), arguing that the complaint asserted patent-ineligible claims under 35 U.S.C. § 101. The district court concluded that the asserted patents are ineligible under § 101.

Hantz maintained that the district court’s ineligibility judgment extended to all claims of the asserted patents, not just claims 1 and 31–33. According to Hantz, any ineligibility judgment should apply to only claims 1 and 31–33 of the asserted patents because Hantz’s operative complaint asserted infringement of only those claims. The Federal Circuit agreed.

Claim 1 of U.S. Patent No. 8,055,5560 is representative and recites:

1. A computer implemented method for Account Payable (AP) accounting for use within a multi-company accounting system that operates on a computer arrangement and which is accessible by one or more persons defining an interface user, the method comprising:

• at a processor, recording a multi-company voucher with the multi-company accounting system, the interface user entering financial data into the multi-company accounting system via the computer arrangement including:
  • entering a voucher total money amount; and
  • entering input voucher detail lines, each of the input voucher detail lines having an entered account associated with one of a plurality of companies of a multi-company group and an amount of money, at least two of the input voucher detail lines being associated with two distinct companies of the multi-company group, wherein the distinct companies are affiliated with each other and wherein each uses the multi-company accounting system for tracking money flow and balancing balance sheets for their respective accounting operations;
• at the processor, automatically adding via the multi-company accounting system at least a pair of multi-company generated balancing lines associated with the multi-company voucher for balancing money owed by each of the distinct companies to define an outstanding balance associated with each of the distinct companies, thereby keeping Accounts Payable for each of the distinct companies in balance;
• at the processor, creating a payment for paying the multi-company voucher including the interface user entering an amount of the payment into the multi-company accounting system via the computer arrangement; and
• at the processor, recording the payment with the multi-company accounting system to reduce the outstanding balances for the distinct companies including the multi-company accounting system automatically adding at least a pair of multi-company generated Due To/Due From lines as Due To/Due From entries to balance the money owed between the distinct companies, thereby keeping Accounts Payable for each of the distinct companies in balance.

The Federal Circuit found that this claim was patent-ineligible.