Epicor Software Corp. v. Protegrity Corp.

Epicor Software Corp. v. Protegrity Corp., CBM No. 2015-00002 and 2015-00006 (Turner, Petravick, and Anderson, ALJ) (April 18 and 20, 2016)

Patent(s):    

  • 6,321,201 | Entitled, “Data Security System for a Database having Multiple Encryption Levels Applicable on a Data Element Value Level”
  • 8,402,281 | Entitled, “Data Security System for a Database” 

Disposition:               

Certain claims found to be unpatentable as directed to non-statutory subject matter.  

Abstract Idea:

Yes 

Something More:

No 

Technology:              

Method and system for managing access to a database. 

Summary:                 

The Panel characterized the independent claim under examination as the steps of storing data in databases, where some data are stored as encrypted data element values, associated with a data element type, and a plurality of data processing rules, associated with a data element type, are stored in a separate data protection catalogue. The Panel found that the claim was directed to an abstract idea: “claim 1 conveys nothing more meaningful than the fundamental concept of determining whether access to data should be granted based on whether one or more rules are satisfied.” Finally, the panel held that the recited structures for performing those steps are routine and conventional. 

Interestingly, the Panel found the declarations of Patentee’s experts unconvincing at demonstrating that the invention cured a problem rooted in computer technology, though they argued that the patented invention had been used to safeguard the Coca-Cola formulation from lower level employee access.

As to certain other dependent claims, the Panel found that the patent challenger had not met its burden of demonstrating that the additional elements in those claims were not material. This ruling was based on a failure to provide supporting evidence, rather than a substantive evaluation of the elements of the dependent claims.