[2] The Federal Circuit reversed the district court's summary judgment ruling that all claims were patent–ineligible abstract ideas under Alice.
In a standard, conventional relational database, each entity (i.e., each type of thing) that is modeled is provided in a separate table.
[5] Enfish's patents assert that the self-referential arrangement has several advantages: faster look-ups, more efficient storage of data other than structured text, no requirement to model each thing in the database as a separate table, and thus the ability to be "configured on-the-fly."
Given these observations, the Court determines that the claims are addressed to the abstract purpose of storing, organizing, and retrieving memory in a logical table.
[7]The court then proceeded to the second step of the Alice analysis, which is to determine whether "the claims contain additional limitations that amount to an inventive concept."
[10] The Federal Circuit rejected the conclusion of district court Judge Pfaelzer that the claims were abstract, and rejected the argument that the claims are 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 said that "the district court oversimplified the self-referential component of the claims and downplayed the invention's benefits."
"[15] Several district courts have reacted to Enfish already, in cases in which they had granted summary judgment motions on grounds of lack of patent eligibility under Alice.
In Mobile Telecommunications Technologies v. Blackberry Corp. in the Northern District of Texas, the court requested supplemental briefs on the Enfish decision.
In Activision Publishing Inc. v. xTV Networks, Ltd.[16] in the Central District of California, the court requested technology tutorials on the effect of Enfish.
He also emphasizes the court's nod to "the importance of software and the potential for innovation therewith", pointing to the opinion's statement: Much of the advancement made in computer technology consists of improvements to software that, by their very nature, may not be defined by particular physical features but rather by logical structures and processes .
TLI, on the other hand, reaffirms that merely using generic computer technology to carry out a procedure does not add patentable weight to a claimed invention.
inventions are at risk in a post-Alice world," but advises: Nonetheless, if we accept that we have to live in the world of Alice at least for now, the distinction between Enfish and TLI is critical to understand, as it provides a roadmap to patent-eligibility for a great many software inventions.● Michael Mireles, in The IP Kat, counts judicial noses on the patent eligibility of computer-implemented inventions.
There are now five Federal Circuit judges who appear to lean toward favoring patentability of computer-implemented inventions: Hughes, Moore, Taranto, Chen and Wallach.
Importantly, Enfish provides important guidance for step one analysis under Alice and a general attitude supporting patent eligibility for computer-implemented inventions.● Steve Marshall found the Federal Circuit's efforts at harmonization a failure and saw the two opinions as addressing similar technologies but treating them disparately: Despite the attempted harmonizing discussion of Enfish in TLI, the latter exposes several inconsistencies between the opinions as well as potential flaws in the reasoning of Enfish.
As an initial matter, the Federal Circuit's descriptions of the claimed technologies in each of the opinions share similarities in areas that impacted the legal analysis.
"In contrast, the TLI court lambasted the claimed image database using classification data for failing to improve the recited telephone unit or server."
He concludes that these cases "fail the public" in performing the needed "notice function of software patent claims," for "[b]etween the endpoints of firmware that makes a machine functional and software that does little more than use a computer as a calculator lay applications that, based on Enfish and TLI, may or may not be patent eligible."
● Gene Quinn in the IPWatchdog applauds the Enfish decision as restoring the legitimacy of software patents: The Federal Circuit also explicitly put a nail in the coffin of the ridiculous argument that software shouldn't be patent eligible if it could run on a general-purpose computer.
The Federal Circuit explained: "We are not persuaded that the invention's ability to run on a general-purpose computer dooms the claims."
In the meantime, however, this case will bring cheer to the heart of those who have been long frustrated by what had seemingly become a de facto rule that software was not patent eligible in the United States.● Brian Mudge and Christopher Gresalfi examine the impact of Enfish on Covered Business Method proceedings within the PTO in the IPR Blog.
[25] In the Informatica case, the PTO considered claims to a system and method for protecting data against unauthorized access.
The PTO found the claimed invention was directed to the abstract idea of "rule based data access."
In the Mirror World case, the patent claimed a method and apparatus for organizing "data units" (i.e., documents) into "streams" and "substreams."
In Informatica the PTO found that the patent just claimed well-known computer elements carrying out routine steps.