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Enfish, LLC v. Microsoft Corp.

Enfish, LLC v. Microsoft Corp.

United States Court of Appeals for the Federal Circuit

May 12, 2016, Decided

2015-1244

Opinion

 [*1330]  [***1685]   Hughes, Circuit Judge.

Enfish sued Microsoft for infringement of several patents related to a "self-referential" database. On summary judgment, the district court found all claims invalid as ineligible under § 101, some claims invalid as anticipated under § 102, and one claim not infringed. Enfish appeals. We find that the claims are not directed to an [**2]  abstract idea, so we reverse the summary judgment based on § 101. We find that the "pivot table" feature of the prior art Excel product does not contain the "self-referential" feature of the claims, so we vacate the summary judgment based on § 102. Lastly, we find no error in the district court's  [***1686]  determination on non-infringement, so we affirm the summary judgment of non-infringement. We remand the case for further proceedings.

Microsoft develops and sells a variety of software products, including the product ADO.NET. At least through the late 1990s and early 2000s, Enfish developed and sold software products, including a new type of database program.

Enfish received U.S. Patent 6,151,604 and U.S. Patent 6,163,775 in late 2000. Both claim priority to the same application filed in March 1995.

The '604 and '775 patents are directed to an innovative logical model for a computer database. A logical model is a model of data for a computer database explaining how the various elements of information are related to one another. A logical model generally results in the creation of particular tables of data, but it does not describe how the bits and bytes of those tables are arranged in physical memory devices. Contrary to conventional logical models, the patented [**3]  logical model includes all data entities in a single table, with column definitions provided by rows in that same table. The patents describe this as the "self-referential" property of the database. '604 patent, col. 2 ll. 44-52.

This self-referential property can be best understood in contrast with the more standard "relational" model. With the relational model, each entity (i.e., each type of thing) that is modeled is provided in a separate table. For instance, a relational model for a corporate file repository might include the following tables:

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822 F.3d 1327 *; 2016 U.S. App. LEXIS 8699 **; 118 U.S.P.Q.2D (BNA) 1684 ***

ENFISH, LLC, Plaintiff-Appellant v. MICROSOFT CORPORATION, FISERV, INC., INTUIT, INC., SAGE SOFTWARE, INC., JACK HENRY & ASSOCIATES, INC., Defendants-Appellees

Prior History:  [**1] Appeal from the United States District Court for the Central District of California in No. 2:12-cv-07360-MRP-MRW, Senior Judge Mariana R. Pfaelzer.

Enfish, LLC v. Microsoft Corp., 56 F. Supp. 3d 1167, 2014 U.S. Dist. LEXIS 156760 (C.D. Cal., 2014)

Disposition: REVERSED-IN-PART, VACATED-IN-PART, AFFIRMED-IN-PART, AND REMANDED.

CORE TERMS

row, column, district court, self-referential, corresponding, algorithm, patents, database, invention, abstract idea, cells, stored, anticipate, indexing, pivot, configuring, specification, recited, software, memory, summary judgment, conventional, technology, invalid, LABEL, infringe, three-step, plurality, Dairy, patent-eligible

Civil Procedure, Summary Judgment, Appellate Review, Standards of Review, Patent Law, Subject Matter, Utility Patents, Process Patents, Computer Software & Mental Steps, Specifications, Description Requirement, Means Plus Function, Anticipation & Novelty, Business & Corporate Compliance, Patent Law, Infringement Actions, Infringing Acts