SAP AMERICA, INC. v. INVESTPIC, LLC, 17-2081, decided May 15, 2018

U.S. Patent No. 6,349,291, directed to statistical analysis of investment information.

Even assuming innovative techniques, claims directed to nothing but a series of mathematical calculations with display of a plot in finance are ineligible (pages 2 and 3).  The improvement is generally resampling to deal with heavily tailed distribution in statistical analysis (pages 3-4).  The claims recite “(a) selecting a sample space, wherein the sample space includes at least one investment data sample; (b) generating a distribution function using a re-sampled statistical method and a bias parameter, wherein the bias parameter determines a degree of randomness in a resampling process; and, (c) generating a plot of the distribution function” (pages 4-6).  The selection of information, analysis using math, and reporting of the results is abstract (page 8).  McRO was distinguish as creating something physical – lip synchronization and facial expressions where how to create this display is recited (page 9).  Here, the improvement is in the math itself, so the claims are abstract (page 11).  There is nothing inventive about any of the claim details where the invention is not itself abstract (page 13).

Hindsight:  Good luck with claims directed to finances.  A new way to present information to avoid error or other improvement outside of the math may help.  While statements that the plot output is more accurate may help, this accuracy is keyed to the math and financial aspects rather than the actual display of the plot.