In Amdocs (Israel) Limited v, Openet Telecom, Inc., [2015-1180] the Federal Circuit reversed and remanded the district court’s judgment on the pleadings that U.S. Patent Nos.\u00a07,631,065,\u00a07,412,510, 6,947,984, and\u00a06,836,797 were not directed to patent eligible subject matter under 35 USC 101.<\/p>\n
The patents in suit concerned, inter alia<\/em>, parts of a\u00a0system designed to solve an accounting and billing problem\u00a0faced by network service providers. \u00a0The Federal Circuit outlined the Alice\/May two step framework, and noted that\u00a0its\u00a0cases generally follow the step\u00a0one\/step two Supreme Court format, reserving step two\u00a0for the more comprehensive analysis in search of the\u00a0inventive concept. The Federal Circuit went on to observe that recent cases suggest that\u00a0there is considerable overlap between step one and step\u00a0two, and in some situations this analysis could be accomplished The Federal Circuit said that\u00a0the\u00a0analysis presumably would be\u00a0based on a generally-accepted and understood definition\u00a0of, or test for, what an \u2018abstract idea\u2019 encompasses. \u00a0The Federal Circuit \u00a0conceded that:<\/p>\n a search for a single test or definition in the\u00a0decided cases concerning \u00a7 101 from this court, and indeed\u00a0from the Supreme Court, reveals that at present\u00a0there is no such single, succinct, usable definition or test.<\/p><\/blockquote>\n The Federal Circuit noted that in absence of a defintion,\u00a0the decisional mechanism After reviewing some of its precedent, the Federal Circuit found the claims in the\u00a0\u2019065 Patent were\u00a0much closer to those in\u00a0BASCOM and DDR Holdings than those in Digitech,\u00a0Content Extraction, and In re TLI Commc\u2019ns. Indeed,\u00a0even if we were to agree that claim 1 is directed to an\u00a0ineligible abstract idea under step one, the claim is eligible With respect to the ‘510, ‘984, and ‘797 Patents, the Federal Circuit said these claims were eligible for patenting for reasons similar\u00a0to those that undergirded the eligibility of the \u2019065 patent\u00a0claims. \u00a0With respect to the\u00a0\u2019984 Patent.<\/p>\n <\/p>\n","protected":false},"excerpt":{"rendered":" In Amdocs (Israel) Limited v, Openet Telecom, Inc., [2015-1180] the Federal Circuit reversed and remanded the district court’s judgment on the pleadings that U.S. Patent Nos.\u00a07,631,065,\u00a07,412,510, 6,947,984, and\u00a06,836,797 were not directed to patent eligible subject matter under 35 USC 101. … Continue reading
\nwithout going beyond step one.<\/p>\n
\ncourts now apply is to examine earlier cases in\u00a0which a similar or parallel descriptive nature can be\u00a0seen\u2014what prior cases were about, and which way they\u00a0were decided, which the Court identified as the classic approach of common law.<\/p>\n
\nunder step two because it contains a sufficient “inventive concept.” \u00a0The Federal Circuit concluded the the\u00a0claim entails an unconventional\u00a0technological solution (enhancing data in a distributed\u00a0fashion) to a technological problem (massive record flows
\nwhich previously required massive databases).<\/p>\n