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United States Federal Circuit

Enfish, LLC v. Microsoft Corp., 2015-1244

In an infringement suit involving several patents related to a 'self-referential' database, the District Court's summary judgment, finding all claims invalid as ineligible under section 101, some claims invalid as anticipated under section 102, and one claim not infringed, is: 1) reversed as to summary judgment on section 101, where the claims are not directed to an abstract idea; 2) vacated as to summary judgment on section 102 where the "pivot table" feature of the prior art Excel product does not contain the "self-referential" feature of the claims; and 3) affirmed as to the finding of non-infrigement where there was no error in the district court's determination.

Appellate Information

  • Decided
  • Published 2016/05/12




  • United States Federal Circuit


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