Amdocs (Israel) Limited v. Openet Telecom, Inc., No. 15-1180 (Fed. Cir. 2016)
Annotate this CaseAmdocs's patents concern parts of a system designed to solve an accounting and billing problem faced by network service providers. Each written description describes the same system, which allows providers to account for and bill for internet protocol network communications. The system's components are arrayed in a distributed architecture that minimizes the impact on network and system resources. Each patent explains that this is an advantage over prior art systems that stored information in one location, making it difficult to keep up with massive record flows from the network devices and which required huge databases. The court granted Openet summary judgment of non-infringement and no inequitable conduct and made claim constructions. The Federal Circuit affirmed two constructions, but vacated a third. On remand, following the Supreme Court decision in Alice Corp. v. CLS Bank International (2014), the district court invalidated all four patents as ineligible under 35 U.S.C. 101. The Federal Circuit reversed and remanded. While noting each abstract idea that the district court found to be disqualifying, the court reasoned that the claims at issue, understood in light of their written descriptions, could be eligible for patenting. The claims are not necessarily valid, having not yet been tested for novelty, non-obvious subject matter, and written description and enablement.
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