Motio, Inc. v. BSP Software LLC, et al.

Motio, Inc. v. BSP Software LLC, et al., No. 4:12-cv-647 (Mazzant, J.) (E.D. Tex. Jan. 4, 2016)

Patent(s):

8,285,678 | Entitled, “Continuous integration of business intelligence software”

Disposition:

Denial of Defendant’s Motion for Summary Judgment asserting claims are ineligible under § 101. 

Abstract Idea:

Yes

Something More:

Yes

Technology:

Methods of providing automatic version control to a business intelligence system.

Summary:

The court determined that the claims were directed to the abstract idea of maintaining versions of electronic documents. However, the claims include an “automated agent” which the court found was “something more” than just an abstract idea. The court construed the phrase “automated agent” as “software that interfaces with a business intelligence system to provide automated version control to a business intelligence artifact” and the “provisions of this automated agent to solve the problem of a business intelligence system lacking native version control amounts to significantly more than a patent on the idea of maintaining version of electronic documents”.