The Court of Appeals for the Federal Circuit issued an opinion affirming the district court’s finding that claims to a graphical user interface (GUI) were patent-eligible under 35 U.S.C. § 101.
In Trading Technologies International, Inc. v. CQG, Trading Technologies International charged CQG with infringement of two patents. The patents generally describe and claim a method and system for the electronic trading of stocks, bonds, futures, options and similar products. In particular, the patents describe a trading system in which a GUI “display[s] the market depth of a commodity traded in a market.”
During the district court proceedings, CQG moved for judgment as a matter of law, asserting that the claims of the patents are directed to patent-ineligible subject matter. The district court denied the motion, holding that the claims are not directed to an abstract idea and also that they recite an inventive concept. Regarding the GUI, the district court stated that the specific structure and associated functionality of the GUI, which improves speed, accuracy, usability and function, provided a level of concreteness such that the patent claimed more than abstract ideas. Additionally, the court stated that “[t]he claims require a specific structured graphical user interface paired with a prescribed functionality directly related to the graphical user interface’s structure that addressed to and resolves a specifically identified problem in the prior state of the art.”
The court of appeals agreed with the district court, observing that the patents do not simply claim displaying information on a GUI. Rather, the court of appeals cited to DDR Holdings, LLC v. Hotels.com, and held that specific technological modifications to solve a problem or improve the functioning of a known system generally produce patent-eligible subject matter. By contrast, ineligible claims generally lack steps or limitations specific to the solution of a problem or improvement in the functioning of technology.
Trading Techs. Int’l, Inc. v. CQG, Inc., No. 05-cv-4811 (N.D. Ill. Jan. 18, 2017).