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The Federal Circuit clarified the inquiry for identifying abstract ideas.   Patent claims (even if software related) that “are directed to a specific improvement to the way computers operate,” rather than to “economic or other tasks for which a computer is used in its ordinary capacity,” are not directed to an “abstract idea.”

Enfish’s claims were directed to a data storage and retrieval system comprising a particular logical, table format for storing data on a computer, i.e., a single, “self-referential table” that improved upon the multi-table, relational databases in use at the time.  The district court earlier concluded that the claims were directed to the abstract idea of “storing, organizing, and retrieving memory in a logical table,” or, more simply, “the concept of organizing information in a logical table,” and therefore held that the claims were not patent eligible. The Federal Circuit, however, disagreed and reversed.

The Court started with the Alice test and held that “the first step in the Alice inquiry . . . asks whether the focus of the claims is 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.”  Applying this articulation of the “abstract idea” test to the Enfish claims, the court found that “the claims are not simply directed to any form of storing tabular data, but instead are specifically directed to a self-referential table for a computer database,”  which provided many benefits over conventional databases, such as increased flexibility, faster search times, and smaller memory requirements.  Thus. The district court’s’ characterization of the Enfish claims as “abstract ideas” are improper, because they are at too high a level of abstraction and they ignore the language of the claims, thereby ensuring that the exceptions to Section 101 swallow the rule. 

The Court was also “not persuaded that the invention’s ability to run on a general-purpose computer dooms the claims.” Interestingly, the claims in other cases held to be directed to an “abstract idea,” “can readily be understood as simply adding conventional computer components to well-known business practices” or merely recite “use of an abstract mathematical formula on any general purpose computer.”  

Thus, the court held that the claims in Enfish are not directed to an abstract idea: “[i]n sum, the self-referential table recited in the claims on appeal is a specific type of data structure designed to improve the way a computer stores and retrieves data in memory.”

Enfish, LLC v. Microsoft Corporation, Case No. 2015-1244 (May 12, 2016); Opinion by: Hughes, joined by Moore and Taranto; Appealed From: United States District Court for the Central District of California, Pfaelzer, J. Read the full opinion here.

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