| News |

Recent case law on 35 U.S.C. § 101 : The Federal Circuit, in the decision of Mortgage Grader, Inc v. First Choice Loan Services dated January 20, 2016, affirmed the district court's finding that the claims are directed to patent-ineligible subject matter. The claims-in-suit recite systems and methods of financial transactions including a method for a borrower to evaluate and obtain financing. The Federal Circuit applied the two-step Mayo test as clarified by Alice. In the first step, the court held that the claims, analyzed individually and as a whole, recite nothing more than the abstract idea of "anonymous loan shopping." In the second step, the court reasoned that the claims add only generic computer components that do not satisfy the inventive concept requirement, and that the claims did not solve a problem unique to the Internet and were not adequately tied to a particular machine or apparatus.

| Events |

[May. 2016] Mr. Rabin and Ms. Hori attended the INTA 2016 Annual Meeting in Orlando, FL.

[Mar. 2016] Mr. Rabin, Mr. Berdo, Mr. Jeong and Dr. Zhang visited clients in Japan, Korea and Taiwan in March, and discussed issues of patent practice including sufficiency of disclosure under the current interpretation of §101 and §112, and third party submissions.

[Oct. 2015] Mr. Rabin and Dr. Zhang attended the AIPLA 2015 Annual Meeting in Washington, DC.

[Mar. 2015] Rabin & Berdo is again ranked 49th in "2015 Top Patent Firms" in the United States by Intellectual Property Today magazine, based on the number of U.S. patents the firm prosecuted to issuance during 2014.