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Dealertrack, Inc. v. Huber

July 7, 2009

DEALERTRACK, INC., PLAINTIFF,
v.
DAVID L. HUBER; FINANCE EXPRESS, LLC; JOHN DOE DEALERS, DEFENDANTS.



The opinion of the court was delivered by: Andrew J. Guilford United States District Judge

ORDER GRANTING MOTION FOR SUMMARY JUDGMENT OF INVALIDITY OF '427 PATENT

Defendants Finance Express, LLC ("Finance Express") and RouteOne, LLC ("RouteOne") (collectively, "Defendants") have filed a Motion for Summary Judgment of Invalidity as to U.S. Patent 7,181,427 ("Motion"). Because the Court finds that the '427 Patent is directed to unpatentable subject matter under 35 U.S.C. § 101 and the recent case of In re Bilski, 545 F.3d 943 (Fed. Cir. 2008), Defendants' Motion is GRANTED.

BACKGROUND

Plaintiff DealerTrack, Inc. ("DealerTrack") asserts that Finance Express and RouteOne have infringed three of DealerTrack's patents, including U.S. Patent 7,181,427 (the "'427 Patent"). The '427 Patent, which was issued on February 20, 2007, is entitled "Automated Credit Application System." According to the Abstract, the patent is directed to a "computer based credit application processing system [that] provides a graphical user interface, automatic software update downloading, lender to lender routing of credit applications, and integration with in-house finance and insurance systems and third party data entry facilities, among other features." The background section of the patent explains that before the '427 Patent, most processes for obtaining credit and financing of major consumer purchases had been done manually. (Hadley Decl. Ex. 1 at 1:23-25.) With the invention of the '427 Patent, the "entire indirect loan application processing, routing, and funding" is placed in an environment with graphical user interfaces. (Id. at 1:48-2:56.)

DealerTrack asserts that Defendants have infringed on claims 1, 3, and 4 of the '427 Patent. Claim 1, an independent claim, recites a "computer aided method" of managing a credit application, consisting of the following steps:

[A] receiving credit application data from a remote application entry and display device;

[B] selectively forwarding the credit application data to remote funding source terminal devices;

[C] forwarding funding decision data from at least one of the remote funding source terminal devices to the remote application entry and display device;

[D] wherein the selectively forwarding the credit application data step further comprises:

[E] sending at least a portion of a credit application to more than one of said remote funding sources substantially at the same time;

[F] sending at least a portion of a credit application to more than one of said remote funding sources sequentially until a finding [sic] source returns a positive funding decision;

[G] sending . . . a credit application . . . after a predetermined time . . . ; or;

[H] sending the credit application from a first remote funding source to a second remote finding [sic] source . . . .

Claim 3 recites the method of Claim 1, with the additional steps of "aggregating data for a dealer having a plurality of dealerships located at different locations" and "providing the dealer with a consolidated report using the aggregated data." Claim 4 recites the method of Claim 1, with the additional step of ...


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