iCharts LLC v. Tableau Software, LLC

iCharts LLC v. Tableau Software, LLC The Federal Circuit affirmed, holding that the representative claims were directed to the abstract idea of generating and sharing self-contained interactive charts on computers or across websites. The claims added no inventive concept because they recited desired results without claiming how the charts were generated, rerendered, updated, or made self-contained. The decision reinforces that software claims framed around portable or embeddable interactive content need concrete implementation detail in the claims, not just functional results or field-of-use limits. Affirmed. The district court treated claim 1 of each asserted patent as representative and held the claims ineligible at the pleadings stage. At Alice step one, the Federal Circuit agreed the claims were abstract because they claimed the result of generating and sharing self-contained interactive charts, not a specific way to achieve that result. Limiting the idea to interactive charts or cross-website sharing did not save the claims; the court treated that as a field-of-use limitation. At Alice step two, iCharts' Adobe Flash theory did not change the outcome because the claims did not require Adobe Flash or any particular mechanism for achieving self-contained interactivity. The court also rejected iCharts' procedural argument that the Rule 12(c) motion should have been converted to summary judgment, noting that the district court relied on claim language and patents attached to the complaint. § 101 waiver / forfeiture non-precedential § 101 waiver / forfeiture non-precedential § 101 non-precedential