Overcoming Alice with Technical Solutions

Federal Circuit cases deciding Alice issues have generally found against the patentee when applying the Supreme Court's Alice Abstract Idea test. However, there have been a string of cases finding concepts patentable, including DDR Holdings, Enfish, Bascom, and McRO. The Federal Circuit just announced a new decision, Amdocs, to add to the list.

The case involved four patents related to solving accounting and billing problems faced by network service providers.  As summarized by the Federal Circuit, the four patents are as follows:

The decision focuses on the technical problems solved by the invention, and its ability to minimize the impact on network system resources due to the way the components are arrayed in a distributed architecture. The inclusion of "distributed data gathering, filtering, and enhancements that enable load distribution" "allows data to reside close to the information sources, thereby reducing congestion in network bottlenecks, while still allowing data to be accessible from a central location."  This approach allegedly differed from the prior art that stored information in one location. 

In Amdocs, the court eschews any hope of defining "abstract" and instead tries to cement the common law approach of analyzing previous cases. The opinion then moves through numerous cases, distinguishing those that found the claims abstract and analogizing to the ones finding the claims patentable. It seems a key aspect to the decision was the problem-solution explanations included in the specifications. 

The particular structure to which claim 1 was sufficiently tied included elements such as network devices, gatherers, ISMs, a central event manager, a central database, a user interface, and terminals or clients.

Amdocs represents another example where explaining how the claim includes elements that solve a technical problem in an unconventional way gives a win to the patentee whose patent was challenged under the Supreme Court's Alice test.