In Enfish, LLC v. Microsoft Corp., Appeal No. 2015-1244, the Federal Circuit held that claims directed to computer-database software technology were patent-eligible under § 101.
Enfish brought suit against Microsoft claiming that Microsoft’s ADO.NET product infringed patents directed to a logical model for storing data in a computer database. The district court granted Microsoft’s motion for summary judgment and found all asserted claims invalid under § 101. Enfish appealed.
In the first step of its § 101 analysis under Alice, the Federal Circuit found that the claims at issue were not directed to an abstract idea because the claims were “directed to a specific improvement to the way computers operate.” The court stated that where the focus of the claims is on a “specific asserted improvement in computer capabilities” rather than on “a process that qualifies as an ‘abstract idea,’” a claim can be found to not be directed to an abstract idea without proceeding to the second step of the Aliceanalysis.