Alice in Patentland: Enfish, LLC v. Microsoft

Background – Enfish received U.S. Patent 6,151,604 and U.S. Patent 6,163,775 in late 2000. Enfish sued Microsoft for infringement of these 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 appealed against the district court’s grant of summary judgment on § 101 invalidity, § 102 invalidity, and non-infringement.

Technology Involved – 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.

Trial Proceedings – The court conducted a 2-step Alice test to check the validity of US ’604 and US ’775.

Step 1: Determining whether the asserted claims are directed to an abstract idea.

Finding: The district court had decided that the claims were abstract, and were directed to “the concepts of organizing data into a logical table with identified columns and rows where one or more rows are used to store an index or information defining columns.” The Federal Circuit insisted, “describing the claims at such a high level of abstraction and untethered from the language of the claims all but ensures that the exceptions to § 101 swallow the rule.” The self-referential table recited in the claims on appeal was found to be a specific type of data structure designed to improve the way a computer stores and retrieves data in memory. The specification’s disparagement of conventional data structures, combined with language describing the “present invention” as including the features that make up a self-referential table, confirmed that the characterization of the “invention” for purposes of the § 101 analysis has not been deceived by the “draftsman’s art.” The court found that the claims at issue were not directed to an abstract idea within the meaning of Alice. Rather, they were directed to a specific improvement to the way computers operate, embodied in the self-referential table.

Step 2: Determining the presence of “inventive concept” i.e., an element or combination of elements sufficient to ensure that the patent in practice amounts to significantly more than a patent upon the abstract idea itself.

Finding: Because the claims were not directed to an abstract idea under step one of the Alice analysis, the court did not proceed to step two of the analysis.

Conclusion – The Federal Circuit rejected the conclusion of district court Judge Pfaelzer that the claims were abstract and said that “the district court oversimplified the self-referential component of the claims and downplayed the invention’s benefits.” The Court found that the claims were not directed to an abstract idea, so it reversed the summary judgment based on § 101. The court also found that the “pivot table” feature of the prior art Excel product did not contain the “self-referential” feature of the claims, so it vacated the summary judgment based on § 102. Lastly, it found no error in the district court’s determination on non-infringement.