In re Scott P. Schreer, No. 2012-1564 (Fed. Cir. May 21, 2013).
The Court of Appeals for the Federal Circuit affirmed the Board of Patent Appeals decision that "the claims would have been obvious to one of ordinary skill in the art at the time of invention..." The patent application sought to cure problems relating to the "public performance" right of copyright holders by claiming a method of compensating the copyright holders. "Generally speaking, the claimed method method consists of embedding identification information in an audio file, broadcasting the audio file in a public broadcast, receiving the audio file by a monitoring station, correlating the identification information to a copyright holder, and then compensating the copyright holder."