## Facts

- Enfish, LLC owned U.S. Patent Nos. 6,151,604 and 6,163,775, directed to a logical model for a computer database using a “self-referential” table.
- The claimed model placed all data entities in a single table, with column definitions provided by rows in the same table, differing from conventional relational databases that use separate tables per entity.
- Enfish asserted the design improved computer operation by enabling faster searches, more efficient storage, and greater flexibility in configuring a database.
- Enfish sued Microsoft and others, alleging Microsoft’s ADO.NET infringed claims of the patents.
- The district court granted summary judgment: (a) all asserted claims invalid under 35 U.S.C. § 101 as directed to the abstract idea of “storing, organizing, and retrieving memory in a logical table,” (b) certain claims anticipated under 35 U.S.C. § 102 by prior art including Microsoft Excel’s “pivot table,” and (c) one claim not infringed.
- Enfish appealed the § 101, § 102, and noninfringement rulings.

## Issues

1. Whether the asserted database claims were “directed to” an abstract idea under Alice/Mayo step one, rendering them ineligible under 35 U.S.C. § 101.
2. Whether Excel’s “pivot table” prior art anticipated the asserted claims under 35 U.S.C. § 102.
3. Whether summary judgment of noninfringement as to one asserted claim was proper.

## Decision

- The Federal Circuit reversed the § 101 summary judgment, holding the claims were not directed to an abstract idea at Alice step one.
- The court vacated the § 102 anticipation summary judgment because the pivot table prior art lacked the claimed self-referential feature.
- The court affirmed summary judgment of noninfringement as to one asserted claim.
- The case was remanded for further proceedings consistent with these rulings.

## Legal Principles

- In Alice/Mayo step one, courts must identify what the claims are directed to without oversimplifying the invention at a high level of abstraction.
- Software-related claims are not “directed to” an abstract idea when they focus on a specific improvement to computer functionality (e.g., a particular data structure that changes how a computer stores and retrieves data).
- When a claim is found not abstract at Alice step one, a court need not proceed to step two’s “inventive concept” analysis to uphold eligibility.
- Anticipation under § 102 requires that a single prior-art reference disclose every claimed feature; absence of a required structural feature defeats anticipation.

## Conclusion

The Federal Circuit treated the claimed self-referential table as a concrete improvement to how computers operate, not an abstract idea, reversing § 101 invalidity; it also vacated anticipation because the cited prior art did not disclose the self-referential structure, while leaving intact a separate noninfringement ruling for one claim.


Enfish, LLC v. Microsoft Corp., 822 F.3d 1327 (Fed. Cir. 2016)