Enfish, LLC v. Microsoft Corp.

Enfish, LLC v. Microsoft Corp., No. 2015-1244, 2016 WL 2756255, at *1 (Fed. Cir. May 12, 2016)


  • 6,151,604 | Entitled “Method and apparatus for improved information storage and retrieval system” 
  • 6,163,775 | Entitled “Method and apparatus configured according to a logical table having cell and attributes containing address segments”


Reversing dismissal of Patent Claims. 

Abstract Idea:

No for both patents.

Something More:

No for both patents.


Both patents involve an innovative logical model for a computer database.


The Federal Circuit found both patents to be valid under § 101 because they were “not directed to an abstract idea within the meaning of Alice. Rather, they [were] directed to a specific improvement to the way computers operate.” The Court distinguished two types of patents involving computers: 1) patentable material which focuses on improvement of a computer’s capabilities, and 2) ineligible abstract ideas involving a process for which computers are used as a tool.  Here, because the patents were directed towards improving computer functionality itself, and not toward economic or other tasks for which the computer is used as a tool, the patent is not considered an abstract idea.