DATA ENGINE TECHS. LLC v GOOGLE LLC, decided Oct. 9, 2018, Statutory Subject Matter

U.S. Patent Nos. 5,590,259; 5,784,545; 6,282,551; and 5,303,146 are directed to a user interface with notebook tabs to navigate spreadsheets and other spreadsheet functionality (pages 2-3).  When filed, spreadsheets used complex commands in complex menus or memorization to navigate (pages 3-4).  The “tab” implementation was acclaimed at the time (pages 5-6).  Claim 12 of the ‘259 patent includes a specific technical solution to a technical problem in computers (page 13).  By providing an intuitive, user-friendly interface with familiar tabs, computers provided rapid access to spreadsheet information (pages 13-14).  Implementation details, such as user-settable tab identifiers, navigation using the tabs, and formula relating the identifier to operate on information are recited (page 15).  Claim 12 is not directed to mere navigation using buttons or a generic model (page 15).  The tabs provide a specific structure within a particular display to perform a specific function and provides a specific improvement in operation of the computer (pages 18-19).  The fact that tabs existed outside of computers to organize information does not make claim 12 abstract as the claim as a whole provides for a functional improvement by specifically recited tabs (page 20).  Claim 1 of the ‘551 patent is abstract as reciting mere association of cells to a user-settable page identifier without including the specific notebook tab interface (page 21).  A specific technical solution and improvement is not provided (page 22).   Partitioning cells, referencing in one cell a formula referencing a second page, and saving pages such that they appear as being stored as one file merely implement the abstract idea itself (page 22).  The claims of the ‘146 patent recites creating a base spreadsheet, creating a new spreadsheet, and determining which cells changed by comparison (page 23).  This does not improve spreadsheet functionality in a specific enough way, so the ‘146 claims are abstract (page 23). 

Hindsight:  Keeping records of satisfying unmet needs may be important for proving statutory subject matter.  Providing implementation details in the claims and claims directed to a solution to a well-documented problem may help.  Claims directed to an improvement in user interface for operation of the computer may more likely be directed to statutory subject matter, but specifics of the user interface may be needed.