Law School Case Brief
Enfish, LLC v. Microsoft Corp. - 822 F.3d 1327 (Fed. Cir. 2016)
There is no reason to conclude that all claims directed to improvements in computer-related technology, including those directed to software, are abstract and necessarily analyzed at the second step of Alice, nor is it the case that Alice so directs. Therefore, it is relevant to ask whether the claims are directed to an improvement to computer functionality versus being directed to an abstract idea, even at the first step of the Alice analysis.
Microsoft Corp. develops and sells a variety of software products, including the product ADO.NET. At least through the late 1990s and early 2000s, Enfish LLCdeveloped 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. Enfish sued Microsoft for infringement of several patents related to a "self-referential" database. 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 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. 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. On summary judgment, the district court found all claims invalid as ineligible under 35 U.S.C.S. § 101, some claims invalid as anticipated under 35 U.S.C.S. § 102, and one claim not infringed. Enfish appealed
Did the district court err in finding all claims patent-ineligible under 35 U.S.C.S. §§ 101 et seq.?
The Court of Appeals for the Federal Circuit held that the district court erred in finding all claims patent-ineligible under 35 U.S.C.S. § 101 because the claims were not directed to an abstract idea within the meaning of step one of the Alice analysis. Rather, they were directed to a specific improvement to the way computers operate, embodied in the self-referential table. Because the "pivot table" feature of the prior art Excel product did not contain the "self-referential" feature of the claims, summary judgment based on anticipation under 35 U.S.C.S. § 102 also could not stand. The district court did not err in granting summary judgment of non-infringement because there was no infringement of the particular claim at issue.
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