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Federal Circuit Nixes'Insurance Claims'Under Section 101
On Sept. 5, 2013, the Federal Circuit panel of Judges Rader, Lourie, and Reyna released its opinion in Accenture Global Services, GmBH v. Guidewire Software, Inc., No. 2011-1486. The opinion, by Judge Lourie, affirmed the district court's holding that all system claims of Accenture's patent for generating tasks to be performed in an insurance organization are invalid under 35 U.S.C. '101. The asserted patent, 7,013,284, claims a system that stores information on insurance transactions in a database, and, upon the occurrence of an event, determines which tasks need to be accomplished and assigns those tasks to various individuals to complete them. Slip Op. at 3.
Judge Sue L. Robinson of the District of Delaware held on summary judgment that the '284 patent was 'directed to concepts for organizing data rather than to specific devices or systems, and limiting the claims to the insurance industry does not specify the claims sufficiently to allow for their survival.' Slip Op. at 7 (internal quotations omitted). Judge Robinson held that both the system and method claims were invalid under Section 101, and Accenture appealed the determination regarding the system claims only.
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