The Federal Circuit this month issued another decision finding claims to a computer-implemented invention to be patent-eligible under 35 U.S.C. § 101. In Amdocs (Israel) Ltd. v. Openet Telecom, Inc. (Fed. Cir. Nov. 1, 2016), the Federal Circuit held that claims directed to a distributed architecture for collecting and processing computer network data close to its source met the requirements of the Alice/Mayo framework, and therefore recited patent-eligible subject matter.
In line with recent trends in § 101 jurisprudence, the court employed a “common law” approach of comparing the claims at issue to those in previous eligibility decisions. The Amdocs patents described several technical advantages of the claimed system, including reduced network congestion and bottlenecks while still allowing data to be accessible from a central location. The court likened this to cases such as DDR Holdings, where technical solutions to technical problems were found non-abstract. In particular, the court in Amdocs considered the claimed system to be an unconventional technological solution (enhancing data in a distributed fashion) to a technological problem (massive record flows which previously required massive databases).
Amdocs joins a growing list of Federal Circuit cases that find computer-implemented inventions to be non-abstract, including DDR Holdings, Enfish, BASCOM, and McRO. We’ve posted recently on these decisions and the USPTO’s ensuing guidance.