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United States Court of Appeals for the Federal Circuit
November 1, 2016, Decided
[*1290] [***1528] Plager, Circuit Judge.
This is a patent case, in which the outcome turns on the application of the 'abstract idea' test, a judicially-created limitation on patent eligibility under § 101 of the Patent Act, 35 U.S.C. § 101.
[***1529] Plaintiff-Appellant Amdocs (Israel) Limited ("Amdocs") sued Defendants-Appellees Openet Telecom, Inc. and Openet Telecom Ltd. (collectively, "Openet") for infringing four U.S. Patents, Nos. 7,631,065 ("'065 patent"); 7,412,510 ("'510 patent"); 6,947,984 ("'984 patent"); and 6,836,797 ("'797 patent"). In the wake of Alice Corp. v. CLS Bank International, 134 S. Ct. 2347, 189 L. Ed. 2d 296 (2014), the district court granted Openet's motion [**2] for judgment on the pleadings, finding that the patents were not directed to patent eligible subject matter under § 101. Amdocs appeals.
For the reasons we shall explain, we reverse and remand for further proceedings.
Prosecution History and Technology
Although we need not recapitulate every detail of these patents, we describe them sufficiently for purposes of this opinion. Additional background is available in our opinion from the prior appeal in this case. See Amdocs (Israel) Ltd. v. Openet Telecom, Inc., 761 F.3d 1329, 1331-36 (Fed. Cir. 2014) ("Amdocs I").
The patents in suit concern, inter alia, parts of a system designed to solve an accounting and billing problem faced by network service providers. Each patent descends from U.S. Patent Application No. 09/442,876, which issued as U.S. Patent No. 6,418,467. One of the patents in suit, the '797 patent, issued as a result of a continuation-in-part application, while the other three patents issued as a result of continuation applications.
The '065 patent concerns a system, method, and computer program for merging data in a network-based filtering and aggregating platform as well as a related apparatus for enhancing networking accounting data records. The '510 patent concerns a system, method, and computer program for reporting on the collection of network usage information. [**3] The '984 patent concerns a system and accompanying method and computer program for reporting on the collection of network usage information from a plurality of network devices. The '797 patent concerns a system, method, and computer program for generating a single record reflecting multiple services for accounting purposes.
Full case includes Shepard's, Headnotes, Legal Analytics from Lex Machina, and more.
841 F.3d 1288 *; 2016 U.S. App. LEXIS 19593 **; 120 U.S.P.Q.2D (BNA) 1527 ***
AMDOCS (ISRAEL) LIMITED, Plaintiff-Appellant v. OPENET TELECOM, INC., OPENET TELECOM LTD., Defendants-Appellees
Subsequent History: US Supreme Court certiorari denied by Openet Telecom, Inc. v. Amdocs (Israel) Ltd., 2017 U.S. LEXIS 7008 (U.S., Nov. 27, 2017)
Prior History: [**1] Appeal from the United States District Court for the Eastern District of Virginia in No. 1:10-cv-00910-LMBTRJ, Judge Leonie M. Brinkema.
Amdocs (Israel) Ltd. v. Openet Telecom, Inc., 56 F. Supp. 3d 813, 2014 U.S. Dist. LEXIS 152447 (E.D. Va., Oct. 24, 2014)
Disposition: REVERSED AND REMANDED.
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Civil Procedure, Appeals, Standards of Review, De Novo Review, Patent Law, Jurisdiction & Review, Judgments, Pretrial Judgments, Judgment on Pleadings, Utility Requirement, Proof of Utility, Constitutional Law, Congressional Duties & Powers, Copyright & Patent Clause, Utility Requirement, Utility Patents, Process Patents, Computer Software & Mental Steps, New Uses