Enfish Case Revived after Federal Circuit Overturns Alice Invalidation

  • May 13, 2016

A once-dead lawsuit filed by NPE Enfish, LLC has been revived by the Federal Circuit, which on Thursday reversed an order by District Court Judge Mariana R. Pfaelzer invalidating the asserted claims of the two patents at issue (6,151,604; 6,163,775) under Alice (2015-1244). In a precedential opinion issued on May 12, 2016, the court ruled that Judge Pfaelzer erred in finding that the two patents asserted against Microsoft, which generally relate to an improved type of database architecture employing a self-referential table, were directed to an abstract idea. The Federal Circuit also reversed the lower court’s judgment that certain claims were invalid as anticipated by prior art, but the panel affirmed the earlier holding that Microsoft had not infringed one of the claims at issue.


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