SAS Institute, Inc. v. ComplementSoft, LLC., No. 15-1346 (Fed. Cir. 2016)Annotate this Case
ComplementSoft’s patent, issued in 2006, is directed to an “Integrated Development Environment for generating and maintaining source code . . . in particular, programmed in data manipulation languages,” and characterizes a development environment as comprising a set of software tools allowing users to develop, edit, and debug software for a particular programming language or set of programming languages. The contemplated development environment utilizes a graphical user interface and is particularly designed for data manipulation languages, including SAS®, which is developed by SAS. On SAS's petition for inter partes review, the Patent Trial and Appeal Board found all of the instituted claims, except for claim 4, unpatentable in view of prior art. The Federal Circuit agreed on the challenged constructions and determined that the Board did not need to address claims it did not institute. The court vacated the determination that claim 4 was patentable and remanded for the parties to address a new construction that the Board adopted in its final decision after previously interpreting the claim differently. The court noted that it is uncertain whether SAS will be able to show unpatentability of claim 4 even under the construction of “graphical representations of data flows” that the Board adopted and that it agreed with.
The court issued a subsequent related opinion or order on November 7, 2016.