The Federal Circuit in Enfish LLC v. Microsoft reverses the California District Court decision that several patents related to a “self-referential” database were invalid as ineligible under 35 U.S.C. §101.
On May 12, 2016, the Federal Circuit awarded a victory for software patents — finding that the claims of two software patents directed to an innovative logical model for a computer database were patent-eligible under 35 U.S.C § 101. The Federal Circuit held that the claims at issue were not directed to an abstract idea, and instead were directed to a specific improvement to the way computers operate — relying on the claims and the specification to support the holding. In its holding, the Federal Circuit recognized that software patents can be deemed patent eligible even if (i) the invention is run on a general purpose computer; and (ii) the improvement is not defined by reference to “physical components.”
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