ineligible subject matter : CAFC Alert

Software can make non-abstract improvements to computer technology under 35 USC §101

| June 24, 2016

Enfish, LLC v Microsoft Corp.

May 12, 2016

Precedential Opinion by Hughes, joined by Moore and Taranto.


Enfish sued Microsoft for infringement of several patents related to a “self-referential” table for a database. The district court found all claims invalid as ineligible under § 101 on summary judgment.  The CAFC reversed the summary judgment based on § 101 by finding that claims drawn to a “self-referential” table for a data base are not directed to an abstract idea under step one of the Alice analysis.

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