Enfish, LLC v. Microsoft Corp.

745 Citing cases

  1. Electric Power Group, LLC v. Alstom S.A.

    830 F.3d 1350 (Fed. Cir. 2016)   Cited 552 times   39 Legal Analyses
    Explaining that the claims in Enfish were eligible "because [they] focused not on asserted advances in uses to which existing computer capabilities could be put, but on a specific improvement ... in how computers could carry out one of their basic functions"

    We review the district court's grant of summary judgment of ineligibility de novo. Enfish, LLC v. Microsoft Corp. , 822 F.3d 1327, 1334 (Fed. Cir. 2016). II

  2. BASCOM Global Internet Services, Inc. v. AT&T Mobility LLC

    827 F.3d 1341 (Fed. Cir. 2016)   Cited 489 times   56 Legal Analyses
    Noting that, in some cases involving computer-related claims, "there may be close calls about how to characterize what the claims are directed to," and that in such cases "an analysis of whether there are arguably concrete improvements in the recited computer technology could take place under step two" (quoting Enfish , 822 F.3d at 1339 )

    We have found software-related patents eligible under both steps of the test Alice sets out. We found a patent to a particular improvement to a database system patent-eligible under step one in Enfish LLC v. Microsoft Corp. , 822 F.3d 1327, 1339–40, 2016 WL 2756255, at *8 (Fed. Cir. May 12, 2016). There, we found claim language reciting the invention's specific improvements to help our determination in step one of the Alice framework that the invention was directed to those specific improvements in computer technology.

  3. TLI Communications LLC v. AV Automotive, L.L.C.

    823 F.3d 607 (Fed. Cir. 2016)   Cited 422 times   23 Legal Analyses
    Finding patent claiming "a method for recording, communicating and administering digital image" to be directed to an abstract concept because such claims are "directed to the use of conventional or generic technology in a nascent but well-known environment, without any claim that the invention reflects an inventive solution to any problem presented by combining the two" (citing Enfish, 822 F.3d at 1335)

    We recently clarified that a relevant inquiry at step one is “to ask whether the claims are directed to an improvement to computer functionality versus being directed to an abstract idea.” See Enfish, LLC v. Microsoft Corp., No. 2015–2044, 822 F.3d 1327, 1335, 2016 WL 2756255 (Fed.Cir. May 12, 2016). We contrasted claims “directed to an improvement in the functioning of a computer” with claims “simply adding conventional computer components to well-known business practices,” or claims reciting “use of an abstract mathematical formula on any general purpose computer,” or “a purely conventional computer implementation of a mathematical formula,” or “generalized steps to be performed on a computer using conventional computer activity.”

  4. A Pty Ltd. v. Facebook, Inc.

    1:15-CV-156 RP (W.D. Tex. Aug. 9, 2016)   Cited 2 times
    Denying relief under Rule 60(b) and noting that "Enfish did not depart from [Alice's two-step] framework"

    On March 29, 2016, Plaintiff A Pty Ltd. appealed the Court's entry of final judgment and order granting Defendant judgment on the pleadings to the Federal Circuit. That appeal is still pending. On June 3, 2016, Plaintiff filed its motion for relief from final judgment with this Court, arguing that that the Court should grant the motion despite the pending appeal because of extraordinary circumstances raised by the Federal Circuit's recent opinion in Enfish, LLC v. Microsoft Corp., 822 F.3d 1327 (Fed. Cir. May 12, 2016). Plaintiff argues that Enfish changes the existing 35 U.S.C. § 101 analysis on which this Court's prior ruling turned.

  5. Ancora Techs., Inc. v. HTC Am., Inc.

    908 F.3d 1343 (Fed. Cir. 2018)   Cited 72 times   3 Legal Analyses
    Identifying this passage from Enfish as the key inquiry in cases "involving software innovations"

    We reverse. Under Enfish, LLC v. Microsoft Corp ., 822 F.3d 1327 (Fed. Cir. 2016), and related authorities, we conclude, the claims at issue here are not directed to ineligible subject matter. Rather, we hold, the claimed advance is a concrete assignment of specified functions among a computer’s components to improve computer security, and this claimed improvement in computer functionality is eligible for patenting.

  6. BSG Tech LLC v. Buyseasons, Inc.

    899 F.3d 1281 (Fed. Cir. 2018)   Cited 217 times   5 Legal Analyses
    Noting that the self-referential table in Enfish "enabled programmers to construct databases in new ways that required less modeling and configuring of various tables prior to launch"

    We review a grant of summary judgment under the law of the regional circuit. Enfish, LLC v. Microsoft Corp. , 822 F.3d 1327, 1334 (Fed. Cir. 2016). The Fifth Circuit reviews grants of summary judgment de novo.

  7. Gust, Inc. v. AlphaCap Ventures, LLC

    226 F. Supp. 3d 232 (S.D.N.Y. 2016)   Cited 16 times   1 Legal Analyses
    Distinguishing Enfish LLC v. Microsoft Corp. , 822 F.3d 1327, 1335 (Fed. Cir. 2016)

    As the Federal Circuit recently observed, "fundamental economic and conventional business practices are often found to be abstract ideas, even if performed on a computer." Enfish, LLC v. Microsoft Corp. , 822 F.3d 1327, 1335 (Fed. Cir. 2016). Crowdfunding is one such abstract, fundamental economic arrangement.

  8. Rothschild Location Techs. LLC v. Vantage Point Mapping, Inc.

    CASE NO. 6:15-cv-799-RWS-JDL MEMBER CASE (E.D. Tex. Dec. 5, 2016)   Cited 1 times
    Denying relief under Rule 59(e), noting that " Enfish does not overturn or substantially change the Alice test; rather the decision largely reaffirms the existing case law in clarifying the application of Alice to claims that as a whole are directed to a technological improvement"

    Plaintiff Rothschild and Defendants Geotab, Inc., GoFleet Corporation, Iler Group, Inc., and Quartix Inc. consented (Doc. Nos. 85, 86) to United States Magistrate Judge John D. Love conducting all proceedings in this action and ordering entry of a final judgment (Doc. No. 119). All six remaining Defendants did not consent. Before the Court now is Plaintiff Rothschild Location Technologies, LLC's ("Rothschild") Motion for Reconsideration Pursuant to Fed. R. Civ. P. 59(e) and 60(b) (Doc. No. 122). Plaintiff seeks reconsideration of the Court's ruling in light of the Federal Circuit's decision in Enfish, LLC v. Microsoft Corp., 822 F.3d 1327 (Fed. Cir. May 12, 2016). Also before the Court is Rothschild's Motion for Leave to Supplement Rule 60 Motion for Reconsideration (Doc. No. 126) in light of Bascom Global Internet Services, Inc. v. AT&T Mobility, LLC, et al, 827 F.3d 1341 (Fed. Cir. June 27, 2016).

  9. Core Wireless Licensing S.A.R.L. v. LG Elecs., Inc.

    880 F.3d 1356 (Fed. Cir. 2018)   Cited 194 times   12 Legal Analyses
    Finding the asserted claims were directed to an improved user interface and not the abstract idea of an index, after comparing the asserted claims to claims in Enfish, 822 F.3d at 1336, Thales, 850 F.3d at 1349, Visual Memory LLC v. Nvidia Corp., 867 F.3d 1253, 1259 (Fed. Cir. 2017), and Finjan , Inc. v. Blue Coat Systems, Inc., 879 F.3d 1299 (Fed. Cir. 2018)

    We also ask whether the claims are directed to a specific improvement in the capabilities of computing devices, or, instead, "a process that qualifies as an ‘abstract idea’ for which computers are invoked merely as a tool." Enfish, LLC v. Microsoft Corp. , 822 F.3d 1327, 1336 (Fed. Cir. 2016). We previously have held claims focused on various improvements of systems directed to patent eligible subject matter under § 101.

  10. Finjan, Inc. v. Blue Coat Sys., Inc.

    879 F.3d 1299 (Fed. Cir. 2018)   Cited 178 times   25 Legal Analyses
    Describing Enfish

    In cases involving software innovations, this inquiry often turns on whether the claims focus on "the specific asserted improvement in computer capabilities ... or, instead, on a process that qualifies as an ‘abstract idea’ for which computers are invoked merely as a tool." Enfish, LLC v. Microsoft Corp. , 822 F.3d 1327, 1335–36 (Fed. Cir. 2016). The '844 patent is directed to a method of providing computer security by scanning a downloadable and attaching the results of that scan to the downloadable itself in the form of a "security profile."