A year and four months later the CAFC vacated the preliminary injunctionfinding that the Wash.Dis.Ct. failed to recognize the substantialquestion ofinvalidity asserted by Barnesandnoble.com in their prior artreferences.[12] The technicalcharacteristics of the business method patent which Amazon.com claimed deservedpatent protection was misread by theDistrict Court; the difficulty indiscerning the true nature of the invention goes to the very heart of thevalidity of the e-commercepatents which have been proliferating.Barnesandnoble.com had described in its evidence a service offered by CompuServethat useda "single action ordering technology" that Amazon.com had claimed wasunique to its one click method. The Compuserve system was nota World Wide Web(the Web) application and thus the Wash.Dis.Ct. dismissed this as prior art.Finding that the single action orderingtechniques can be used in variousenvironments other than the Internet and that that the medium in which anapplication is expresseddoes not control an invention's originality the CAFCvacated the injunction. The CAFC's comparison of the CompuServe system andAmazon.com'sone click method reflects an important enlightenment by thejudicial branch. It appears that the courts are coming to recognizethatpatents can not be granted on well known business practices simply because theyare represented in technology that works onthe Internet.


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