2016),[1] is a court case in the United States Federal Court System that ended with a panel decision by the Federal Circuit to uphold the patent eligibility of four patents on a system designed to solve an accounting and billing problem faced by network service providers.

This is one of the few times since the Supreme Court's Alice Corp. v. CLS Bank International decision[3] that the Federal Circuit has held computer software-based patent claims eligible.

That claim provides: A computer program product embodied on a computer readable storage medium for processing network account information comprising: The court found that claim 1 was directed to the abstract idea of "the concept of correlating two network accounting records to enhance the first record."

the claim amounts to 'nothing significantly more than an instruction to apply the abstract idea' of correlating two network accounting records 'using some unspecified, generic' computer hardware."

The claim does not add any specific implementation beyond the abstract idea that information is collected and stored, and reports are generated.

[11]The district court next considered representative claim 1 of the '797 patent, which states: A method for generating a single record reflecting multiple services for accounting purposes, comprising: The court said that "the abstract idea in this claim is to generate a single record reflecting multiple services," and proceeded to step two of the Alice analysis.

The court found it particularly important, indeed crucial, that the components (such as network devices; information source modules; gatherers; a central event manager; a central database; a user interface server; and terminals) of the system: are arrayed in a distributed architecture that minimizes the impact on network and system resources.

Through this distributed architecture, the system minimizes network impact by collecting and processing data close to its source.

Each patent [specification] explains that this is an advantage over prior art systems that stored information in one location, which made it difficult to keep up with massive record flows from the network devices and which required huge databases.

The concept of distribution meant that "the network usage records are processed close to their sources before being transmitted to a centralized manager," which makes the database system work faster and more efficiently.

"Unlike the dissent, however, we find the claims at issue, understood in light of that written description [specification], to be eligible for patenting.

[25]Reyna emphasized that the proper "inquiry is not whether the specifications disclose a patent-eligible system, but whether the claims are directed to a patent ineligible concept.

Merely "[l]imiting the abstract idea to the context in which the information relates to network accounting records is a field-of-use limitation that [under Flook] does not supply an inventive concept.

"[28] Relying on the definition of "enhanced" as meaning "distributed" to confer patent eligibility, as the panel majority and Amdocs do, is incorrect because "claim 1 recites no components or structure over which the work might be 'distributed.'

Other claims, however, he found patent eligible because they not only described functions or goals, but they also recited specific steps or machinery to accomplish them.

"[30] ● Dennis Crouch, in Patently-O, did not "know how important Amdocs will be, but it offers an interesting split decision on the eligibility of software patent claims."

Going forward, the split can be reconciled by another Supreme Court opinion, a forceful Federal Circuit en banc decision, or perhaps by future judicial appointments by President Trump.

He pointed out that the majority's focus on the system's "enhancing data in a distributed fashion [being] an unconventional technological solution .

He then quotes Judge Reyna's dissent that says, "But the inquiry is not whether the specifications disclose a patent-eligible system, but whether the claims are directed to a patent ineligible concept.

But the author, while hopeful of "a respite of sorts," was unsure that "the § 101 fog" confronting patentees would now clear away, because "we are still only one en banc Federal Circuit decision or Supreme Court case away from going back to that murky landscape.

"[32] ● One comment on the case expressed a hope for a change in the direction of post–Alice Federal Circuit decisions, which had overwhelmingly found software and business-method patents invalid: "Perhaps the initial stages of a patent-eligible trend for narrowly drawn software-based patent claims, that are directed to specific, unconventional technological solutions, are underway.

The author argued that the opinion "serves to dispel the myth that it is not possible to obtain patent protection for software-based inventions."