Enfish, LLC v. Microsoft Corp.

Software developer Enfish, LLC (plaintiff) owned U.S. Patents 6,151,604 and 6,153,775 (the ‘604 and ‘775 patents), which related to a self-referential computer database. The self-referential-database model differed from traditional computer databases because the self-referential model contained all relevant data entities in a single table, instead of containing each data entity in separate tables. The patents taught that the self-referential model was beneficial because it allowed data to be searched more quickly and stored more effectively, allowing more flexibility in database configuration. In 2012, Enfish sued Microsoft Corporation (defendant), alleging that Microsoft’s ADO.NET product infringed claims 17, 31, and 32 of the ‘604 patent and claims 31 and 32 of the ‘775 patent. Claim 17 recited a data storage-and-retrieval system for computer memory comprising a means for configuring the memory according to a logical table with rows and intersecting columns, as well as for indexing the table’s data. Claims 31 and 32 described methods for configuring the computer memory according to a logical table and described the table in detail, including the table’s self-referential property. The district court entered summary judgment of noninfringement. The court found that the patents’ claims were invalid under 35 U.S.C. § 101 because they were directed to the unpatentable abstract idea of organizing information in a tabular format. The court also found that claims 31 and 32 of both patents were invalid under 35 U.S.C. § 102 because they had been anticipated by the pivot-table feature of Microsoft Excel 5.0, under which the addition of a row to a raw-data table resulted in the addition of a column to a separate pivot table. Enfish appealed.