Example 6: The Game of Bingo
The following claim was found ineligible by the Federal Circuit in Planet Bingo, LLC v. VKGS LLC, 576 Fed. Appx. 1005 (Fed. Cir. 2014). The patent at issue was U.S. Patent No. 6,398,646. The claim is directed to an abstract idea and has additional elements that do not amount to significantly more than the abstract idea.
The invention relates to an automated Bingo system having the ability to print sets of numbers on tickets on site. The system uses a computer to print the tickets, track the sale of the tickets and to validate winning tickets. The computer stores the specific sets of Bingo numbers for a player and prints the tickets having the player’s specific set of Bingo numbers to enable the player to play his specific Bingo numbers for various sessions of Bingo. The automated system allows for managing all aspects of a Bingo game, including solving tampering problems and minimizing other security risks during Bingo ticket purchases.
Claim 1. A system for managing a game of Bingo which comprises:(a) a computer with a central processing unit (CPU) and with a memory and with a printer connected to the CPU;
(b) an input and output terminal connected to the CPU and memory of the computer; and
(c) a program in the computer enabling:(i) input of at least two sets of Bingo numbers which are preselected by a player to be played in at least one selected game of Bingo in a future period of time;
(ii) storage of the sets of Bingo numbers which are preselected by the player as a group in the memory of the computer;
(iii) assignment by the computer of a player identifier unique to the player for the group having the sets of Bingo numbers which are preselected by the player wherein the player identifier is assigned to the group for multiple sessions of Bingo;
(iv) retrieval of the group using the player identifier;
(v) selection from the group by the player of at least one of the sets of Bingo numbers preselected by the player and stored in the memory of the computer as the group for play in a selected game of Bingo in a specific session of Bingo wherein a number of sets of Bingo numbers selected for play in the selected game of Bingo is less than a total number of sets of Bingo numbers in the group;
(vi) addition by the computer of a control number for each set of Bingo numbers selected for play in the selected game of Bingo;
(vii) output of a receipt with the control number, the set of Bingo numbers which is preselected and selected by the player, a price for the set of Bingo numbers which is preselected, a date of the game of Bingo and optionally a computer identification number; and
(viii) output for verification of a winning set of Bingo numbers by means of the control number which is input into the computer by a manager of the game of Bingo.
Claim 1: Ineligible.
Claim 1 is directed to a system comprising a computer, an input and output terminal, and a program enabling management of the game of Bingo. The claimed system is therefore directed to a statutory category, i.e., a machine (a combination of devices) (Step 1: YES).
The claim is then analyzed to determine whether it is directed to any judicial exceptions. The claim recites program elements (i) through (viii) that describe the steps of managing a game of Bingo, including for example inputting and storing two sets of Bingo numbers, assigning a unique player identifier and control number, and verifying a winning set of Bingo numbers.
Managing the game of Bingo as recited in the claim can be performed mentally or in a computer and is similar to the kind of ‘organizing human activity’ at issue in Alice Corp. Although the claims are not drawn to the same subject matter, the abstract idea of managing a game of Bingo is similar to the abstract ideas of managing risk (hedging) during consumer transactions (Bilski) and mitigating settlement risk in financial transactions (Alice Corp.) Claim 1 describes managing the game of Bingo and therefore is directed to an abstract idea (Step 2A: YES).
Next, the claim is analyzed to determine whether there are additional limitations recited that amount to significantly more than the abstract idea. The claim requires the additional limitations of a computer with a central processing unit (CPU), memory, a printer, an input and output terminal, and a program. These generic computer components are claimed to perform their basic functions of storing, retrieving and processing data through the program that enables the management of the game of Bingo. The recitation of the computer limitations amounts to mere instructions to implement the abstract idea on a computer. Taking the additional elements individually and in combination, the computer components at each step of the management process perform purely generic computer functions. As such, there is no inventive concept sufficient to transform the claimed subject matter into a patent-eligible application. The claim does not amount to significantly more than the abstract idea itself (Step 2B: NO). Accordingly, the claim is not patent eligible.