Enfish, LLC v. Microsoft Corp., No. 15-1244 (Fed. Cir. 2016)Annotate this Case
Enfish’s 604 and 775 patents are directed to an innovative logical model for a computer database. A logical model is a model of data for a computer database explaining how the various elements of information are related to one another. A logical model generally results in the creation of particular tables of data, but it does not describe how the bits and bytes of those tables are arranged in physical memory devices. Contrary to conventional logical models, the patented logical model includes all data entities in a single table, with column definitions provided by rows in that same table. In Enfrish’s suit against Microsoft, alleging infringement, the district court found all claims invalid as ineligible under 35 U.S.C. 101, some claims invalid as anticipated under section 102, and one claim not infringed. The Federal Circuit reversed with respect to section 101, finding that the claims are not directed to an abstract idea, and vacated as to section 102, finding that the “pivot table” feature of the prior art Excel product does not contain the “self-referential” feature of the claims. The court affirmed the finding of non-infringement.