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Federal Circuit: A Computer Database Logical Model Is Not an Abstract Idea If Directed At a Specific Implementation of a Solution to a Problem In the Software Arts
On May 12, 2016, a Federal Circuit panel of Circuit Judges Moore, Taranto, and Hughes issued a unanimous opinion, authored by Judge Hughes, in Enfish, LLC v. Microsoft Corp., Case No. 2015-1244. The panel reversed the district court's grant of summary judgment based on '101, concluding that all five claims on appeal are patent-eligible, vacated the district court's grant of summary judgment based on '102, concluding that the claims are not anticipated, and affirmed the district court's grant of summary judgment of non-infringement, concluding that Microsoft's software product ADO.NET does not infringe.
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