Amdocs (Israel) Limited v. Openet Telecom, Inc.

Amdocs (Israel) Limited v. Openet Telecom, Inc., No. 2015-1180 (Fed. Cir. Nov. 1, 2016) (Newman, Plager, and Reyna) (November 1, 2016)

Patent(s):

  • 7,631,065 | Entitled, “System, method and computer program product for merging data in a network-based filtering and aggregating platform” 
  • 7,412,510 | Entitled, “System, method and computer program product for reporting on the collection of network usage information”

  • 6,947,984 | Entitled, “System, method and computer program product for reporting in a network-based filtering and aggregating platform”

  • 6,836,797 | Entitled, “System, method and computer program product for network record synthesis”

Disposition:               

Reversal of district court’s judgment finding the patents ineligible under § 101.

Abstract Idea:

Yes

Something More:

Yes

Technology:              

A system which allows network service providers to account for and bill for internet protocol (“IP”) network communications.

Summary:                 

The Federal Circuit found that the claims of each of the patents entail an unconventional technological solution (enhancing data in a distributed fashion) to a technological problem (massive record flows which previously required massive databases). 

The system described in the patents includes: network devices; information source modules (“ISMs”) which send IP usage data in real time from network devices to “gatherers”; “gatherers” which gather information from the ISMs, normalize data from the various types of ISMs, and serve as a distributed filtering and aggregation system; a central event manager (“CEM”) which provides management and control of the ISMs and gatherers; a central database; a user interface server; and terminals or clients. The patents describe that the components of the system are arrayed in a distributed architecture that minimizes the impact on network and system resources by collecting and processing data close to its source, thereby reducing congestion and network bottlenecks. 

The claims-at-issue require or depend upon enhancing data in a distributed fashion. That is, the claims require a specific structure of various components; the components are not merely combined in a generic manner, but instead are purposefully arranged in a distributed architecture. Though the solution requires arguably generic components, the Federal Circuit found that the claim’s enhancing limitation necessarily requires that the generic components operate in an unconventional manner to achieve an improvement in computer functionality.