{"id":1025,"date":"2016-08-21T11:52:28","date_gmt":"2016-08-21T11:52:28","guid":{"rendered":"http:\/\/www.citiusminds.com\/blog\/?p=1025"},"modified":"2021-02-09T11:38:10","modified_gmt":"2021-02-09T17:38:10","slug":"alice-enfish-microsoft","status":"publish","type":"post","link":"https:\/\/www.citiusminds.com\/blog\/alice-enfish-microsoft\/","title":{"rendered":"Alice in Patentland: Enfish, LLC v. Microsoft"},"content":{"rendered":"\n\n\n\n\n\n\n
Plaintiff<\/strong><\/td>\nEnfish, LLC<\/td>\n<\/tr>\n
Defendant<\/strong><\/td>\nMicrosoft Corp.<\/td>\n<\/tr>\n
Case<\/strong><\/td>\n2:12-cv-07360<\/td>\n<\/tr>\n
Judge<\/strong><\/td>\nTodd M. Hughes (United States Circuit Judge)<\/td>\n<\/tr>\n
Decision Date<\/strong><\/td>\nMay 12, 2016<\/td>\n<\/tr>\n<\/tbody>\n<\/table>\n

Background<\/strong> \u2013 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 \u201cself-referential\u201d database. On summary judgment, the district court found all claims invalid as ineligible under \u00a7 101, some claims invalid as anticipated under \u00a7 102, and one claim not infringed. Enfish appealed against the district court\u2019s grant of summary judgment on \u00a7 101 invalidity, \u00a7 102 invalidity, and non-infringement.<\/p>\n

Technology Involved<\/strong> \u2013 The \u2019604 and \u2019775 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.<\/p>\n

Trial Proceedings<\/strong> \u2013 The court conducted a 2-step Alice test to check the validity of US \u2019604 and US \u2019775<\/strong>.<\/p>\n

Step 1<\/strong>: Determining whether the asserted claims are directed to an abstract idea.<\/p>\n

Finding:<\/strong> 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 \u00a7 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\u2019s disparagement of conventional data structures, combined with language describing the \u201cpresent invention\u201d as including the features that make up a self-referential table, confirmed that the characterization of the \u201cinvention\u201d for purposes of the \u00a7 101 analysis has not been deceived by the \u201cdraftsman\u2019s art.\u201d 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.<\/p>\n

Step 2<\/strong>: Determining the presence of \u201cinventive concept\u201d 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.<\/p>\n

Finding<\/strong>: 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.<\/p>\n

Conclusion<\/strong> \u2013 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 \u00a7 101. The court also found that the \u201cpivot table\u201d feature of the prior art Excel product did not contain the \u201cself-referential\u201d feature of the claims, so it vacated the summary judgment based on \u00a7 102. Lastly, it found no error in the district court\u2019s determination on non-infringement.<\/p>\n","protected":false},"excerpt":{"rendered":"

Plaintiff Enfish, LLC Defendant Microsoft Corp. Case 2:12-cv-07360 Judge Todd M. Hughes (United States Circuit Judge) Decision Date May 12, 2016 Background \u2013 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 \u201cself-referential\u201d database. On summary judgment, the district court found all […]<\/p>\n","protected":false},"author":1,"featured_media":0,"comment_status":"open","ping_status":"open","sticky":false,"template":"","format":"standard","meta":{"footnotes":""},"categories":[15],"tags":[50,54,53,60,62],"class_list":["post-1025","post","type-post","status-publish","format-standard","hentry","category-alice-motions","tag-abstract-idea","tag-alice","tag-inventive-concept","tag-microsoft","tag-patentland"],"_links":{"self":[{"href":"https:\/\/www.citiusminds.com\/blog\/wp-json\/wp\/v2\/posts\/1025","targetHints":{"allow":["GET"]}}],"collection":[{"href":"https:\/\/www.citiusminds.com\/blog\/wp-json\/wp\/v2\/posts"}],"about":[{"href":"https:\/\/www.citiusminds.com\/blog\/wp-json\/wp\/v2\/types\/post"}],"author":[{"embeddable":true,"href":"https:\/\/www.citiusminds.com\/blog\/wp-json\/wp\/v2\/users\/1"}],"replies":[{"embeddable":true,"href":"https:\/\/www.citiusminds.com\/blog\/wp-json\/wp\/v2\/comments?post=1025"}],"version-history":[{"count":0,"href":"https:\/\/www.citiusminds.com\/blog\/wp-json\/wp\/v2\/posts\/1025\/revisions"}],"wp:attachment":[{"href":"https:\/\/www.citiusminds.com\/blog\/wp-json\/wp\/v2\/media?parent=1025"}],"wp:term":[{"taxonomy":"category","embeddable":true,"href":"https:\/\/www.citiusminds.com\/blog\/wp-json\/wp\/v2\/categories?post=1025"},{"taxonomy":"post_tag","embeddable":true,"href":"https:\/\/www.citiusminds.com\/blog\/wp-json\/wp\/v2\/tags?post=1025"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}