On November 19, 2019, the Patent Trial and Appeal Board (PTAB) vacated a December 2018 PTAB decision which granted Covered Business Method (CBM) review in the patent infringement matter of Apple, Inc. v. Universal Secure Registry LLC.
The PTAB’s decision to vacate was prompted by the U.S. Court of Appeals for the Federal Circuit’s recent opinion in IBG LLC v. Trading Technologies International, Inc., which found that certain patent claims at issue were not abstract because they were “directed to a specific improvement to the way computers operate.” Citing to the IBG decision, the PTAB terminated CBM review of Universal’s patent, finding the claims to be “directed to an improvement in the security of mobile devices” and therefore not abstract under 35 U.S.C. § 101.
