PTAB

CBM2014-00186

1 Travelers Lloyds Of Texas Insurance Co 2 Travelers Indemnity Co v. Integrated Claims Systems LLC

Key Events

Petition

petition

Patent #: 7,346,768
Filed: September 17, 2014
Petitioner(s): Travelers Lloyds of Texas Insurance Company and The Travelers Indemnity Company
Patent Owner(s): Integrated Claims Systems, LLC
Challenged Claims: 1, 6, 10-17, and 28-31

Title: Attachment Integrated Claims Systems and Operating Methods Therefor
Brief Description: The ’768 patent discloses systems and methods for electronically preparing and processing digital insurance claims. The invention is described as a solution to the inefficiency of manually processing hard-copy paper claims, aiming to create a computerized, industry-wide system for moving claims data between healthcare providers and insurance companies.

Prior Art Relied Upon: Not applicable (challenge under 35 U.S.C. §101).
Core Argument for this Ground:
- Prior Art Mapping: Petitioner argued that the challenged claims are directed to the abstract idea of moving and processing data, a concept long found to be unpatentable. The petition asserted that the claims simply apply this abstract idea to a specific field—the insurance industry—using only conventional and generic computer technology. Independent claim 1 and its dependent claims were characterized as merely adding computer systems, a digitizer (scanner), and network communications to the pre-existing manual process of submitting insurance claims.
- Key Aspects: Petitioner contended that the claims add no "inventive concept" beyond the abstract idea itself. The argument highlighted that the ’768 patent admits the recited components (personal computers, modems, scanners, mainframe computers) were all well-known and that the claimed process merely automates a fundamental economic practice. The petition further asserted that the claims fail the machine-or-transformation test, as they are not tied to a particular machine beyond a generic computer and do not transform any article into a different state or thing, merely manipulating data.

Prior Art Relied Upon: Toy (Patent 4,554,418).
Core Argument for this Ground:
- Prior Art Mapping: Petitioner asserted that Toy, which issued more than a decade before the ’768 patent’s priority date, discloses every element of claim 1. Toy describes an electronic system for monitoring financial market data, comparing it against user-specified trigger values, and transmitting notification messages to users. Petitioner’s claim chart mapped Toy’s data processing system (260) to the ’768 patent’s "first computer system." Toy's system accepts user-defined conditions (input 261 from console 262), which Petitioner mapped to the limitation of accepting "data input into a first set of identifiable fields."
- Key Aspects: Petitioner argued that Toy’s generation of a notification message for a user whose trigger values have been met directly corresponds to the ’768 patent’s limitation of generating a "first file containing a second set of the identifiable fields." Furthermore, Toy’s transmission of this notification message to a user’s home computer via a telephone network was argued to meet the ’768 patent’s limitation of transmitting the file over a "communications channel to a second computer system." The argument extended to subsequent users, mapping Toy's capability to notify multiple users to the limitations regarding a "second file" and "third computer system."

"subset": Petitioner proposed this term be construed as "a part of a set that is less than its entirety." This construction was argued to be supported by the specification, which describes an insurance company desiring only a "particular subset of the total number of fields."
"adapted to accept data input into a first set of identifiable fields": Petitioner proposed this phrase be construed as "adapted to accept information from a user input device of the first computer system into a first set of identifiable fields." This construction was intended to emphasize that the claims merely recite generic data entry on a standard computer, a feature Petitioner argued was conventional.
"communications channel": Petitioner argued this term should be construed as an "electronic transmissions path." This broad construction, supported by specification examples like modems and phone lines, was used to align the claim scope with the disclosures in the prior art and to underscore the conventional nature of the technology.

Covered Business Method (CBM) Patent: A central argument was that the ’768 patent is a Covered Business Method patent under the America Invents Act (AIA), making it eligible for Post-Grant Review. Petitioner contended the claims are directed to processing "digital insurance claims," which constitutes a financial product or service. This was supported by the patent’s own text and the patent owner’s litigation behavior of suing numerous insurance companies.
Not a "Technological Invention": Petitioner asserted the ’768 patent does not qualify for the "technological invention" exception to CBM review. The argument was that the claims fail to recite a novel and unobvious technological feature, instead relying entirely on conventional computer hardware to solve a logistical business problem (moving data) rather than a technical one. The patent’s own admissions that the underlying computer components were known in the art were heavily cited to support this point.

Petitioner requested the institution of a Post-Grant Review and the cancellation of claims 1, 6, 10-17, and 28-31 of the ’768 patent as unpatentable under 35 U.S.C. §101 and/or §102.