Case: Accenture Global Servs., GmbH v. Guidewire Software Inc., No. 2011-1486 (Fed. Cir. Sept. 5, 2013). On appeal from D. Del. Before Rader (C.J.), Lourie, and Reyna.

Procedural Posture: Plaintiff appealed summary judgment of invalidity. CAFC affirmed, holding that the system claims at issue recited patent-ineligible subject matter under 35 U.S.C. § 101.

  • Patent Eligibility: System claims were held invalid under § 101 because they did not recite any specific hardware to differentiate the claims from method claims that had been held invalid by the district court. The system claims merely applied the method claims on a computer. Accordingly, the system claims were determined to contain insignificant material limitations beyond the limitations of the invalid method claims. Plaintiff did not appeal the invalidity of the method claims.