An interesting case involving the patentability of database models came out of the Federal Circuit in Enfish, LLC v. Microsoft Corp. where the Court held that two patents covering a new type of database model were not invalid. This is a significant and positive development for software patent owners that goes against recent case law. In the last two years, district courts across the country have overwhelmingly stricken down software patents, including patents in databases. Now, software patent owners have greater support in claiming protection in software, including the software in databases.
The Enfish Decision
The Enfish patents are directed to a logical model for a computer database. A logical model is a model of data for a computer database explaining how the various elements of information are related to one another. Unlike conventional logical models, Enfish’s patented logical model includes all data entities in a single table, with column definitions provided by rows in that same table. The Enfish patents describe this as the “self-referential” property of the database. Enfish sued Microsoft for infringement of Enfish’s patents related to its “self-referential” database. In turn, Microsoft challenged the validity of the Enfish patents, asking the district court to strike down the asserted Enfish patents.
The district court granted summary judgment to Microsoft finding, among other things, that the claims in the Enfish patents were abstract pursuant to Section 101. The district court 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 using tabular formats.”
The Federal Circuit disagreed and reversed the district court’s grant of summary judgment. The Court reasoned that, because the subject claims were directed towards improving computer functionality, the claims were not directed to an abstract idea. Finding no “reason to conclude that all claims directed to improvements in computer-related technology, including those directed to software, are abstract . . . ,” the Federal Circuit expressly held that when “the plain focus of the claims is on an improvement to computer functionality itself, not on economic or other tasks for which a computer is used in its ordinary capacity,” the claims should not be deemed to be directed to an abstract idea.
The Enfish decision establishes that software – in particular, database software – is patent eligible. Patent attorneys should still carefully draft software patent claims with specificity and in direct relation to the application of the technology. Also, companies attempting to secure protection in software should identify the unconventional manner in which the software functions and any palpable benefits over conventional methods.