CAFC reminds 101 victim: “relying on a computer to perform routine tasks more quickly or more accurately is insufficient to render a claim patent eligible.”

From the Shortridge case:

To determine whether a patent claims ineligible subject
matter, we apply the now-familiar two-step test
introduced in Mayo, id. at 1296–97, and further explained
in Alice, 134 S. Ct. at 2355. First, we determine whether
the claims at issue are directed to a patent-ineligible
concept such as an abstract idea. Alice, 134 S. Ct. at
2355. Second, we look at the claims for “something more”
by “examin[ing] the elements of the claim to determine
whether it contains an ‘inventive concept’ sufficient to
‘transform’ the claimed abstract idea into a patent-eligible
application.” Id. at 2354, 2357 (quoting Mayo, 132 S. Ct.
at 1294, 1298). This inventive concept must do more than
simply recite “well-understood, routine, conventional
activity.” Mayo, 132 S. Ct. at 1298.

(...)

What Mr. Shortridge relies on most heavily as the
step-two inventive concept is the generation of CPRs “in
conjunction with and simultaneous with” core payroll
processing. Appellant Br. 11–13 (quoting ’933 patent
col. 18 ll. 62–63, col. 20 ll. 8–9, col. 22 l. 4). We disagree
that this feature imparts patent eligibility. As disclosed
in the specification and recited in the plain claim language,
the ’933 patent claims generating CPRs in conjunction
with and simultaneous with core payroll
processing simply by applying computer elements such as
relational databases. The district court found, and
Mr. Shortridge does not argue to the contrary, that the
computer components contemplated by the ’933 patent
were conventional and known to the industry at the time
of the patent. Dist. Ct. Op., 2015 WL 1739256, at *12.
While it may be true that, as Mr. Shortridge argues, a
human could not easily process core payroll while simultaneously
generating CPRs, “relying on a computer to
perform routine tasks more quickly or more accurately is
insufficient to render a claim patent eligible.”