Improvement to computer functionality is not an abstract idea under step one of the Mayo/Alice framework. Here, for example, claims directed to a “self-referential” logical model for a computer database were found to be sufficiently concrete rather than abstract because they focused on an improvement to computer functionality itself, not on economic or other tasks for which a computer is used in its ordinary capacity. “The ‘directed to’ inquiry … cannot simply ask whether the claims involve a patent-ineligible concept, … [but rather] applies a stage-one filter to claims, considered in light of the specification, based on whether ‘their character as a whole is directed to excluded subject matter.’” This would be a good case to consult and cite in response to a subject matter eligibility rejection predicated on an overly broad assertion of an abstract idea for computer-related inventions.
Background / Facts: The patents being asserted here are directed to a “self-referential” logical model for a computer database. Contrary to conventional logical models, the patented logical model includes all data entities in a single table, with column definitions provided by rows in that same table. The patents teach that multiple benefits flow from this design.
Issue(s): Whether improvement to computer functionality is an abstract idea that warrants further scrutiny under step two of the Mayo/Alice framework.
Holding(s): No. Recognizing that in this case “the plain focus of the claims is on an improvement to computer functionality itself, not on economic or other tasks for which a computer is used in its ordinary capacity,” the court found that “the claims at issue in this appeal are not directed to an abstract idea within the meaning of Alice.” To find otherwise by “describing the claims at such a high level of abstraction and untethered from the language of the claims all but ensures that the exceptions to § 101 swallow the rule.” In advocating for a rebalancing of the Mayo/Alice inquiry, the court emphasized that “the first step of the inquiry is a meaningful one” and presupposes “that a substantial class of claims are not directed to a patent-ineligible concept. The ‘directed to’ inquiry, therefore, cannot simply ask whether the claims involve a patent-ineligible concept, because essentially every routinely patent-eligible claim involving physical products and actions involves a law of nature and/or natural phenomenon—after all, they take place in the physical world. [] Rather, the ‘directed to’ inquiry applies a stage-one filter to claims, considered in light of the specification, based on whether ‘their character as a whole is directed to excluded subject matter.’ … We do not read Alice to broadly hold that all improvements in computer-related technology are inherently abstract and, therefore, must be considered at step two.”