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Amdocs (Israel) Limited v. Opennet Telecom, Inc., et al.

Representative Claim

  1. (‘065 patent) A computer program product embodied on a computer readable storage medium for processing network accounting information comprising:

computer code for receiving from a first source a first network accounting record;

computer code for correlating the first network accounting record with accounting information available from a second source; and

computer code for using the accounting information with which the first network accounting record is correlated to enhance the first network accounting record.

Posture:

Appeal from the the United States District Court for the Eastern District of Virginia. The District Court granted Openet’s motion for judgment on the pleadings, finding that the patents were not directed to patent eligible subject matter under § 101.

Abstract Idea: Undecided

What relative level of abstraction should we employ? From a macroscopic perspective, claim 1 could be described as focusing on correlating two network accounting records to enhance the first record. Claim 1 could also be described in several other ways—such as focusing on a computer program that includes computer code for receiving initial information, for correlating that initial information with additional information, and for using that additional information to enhance the initial information.

Indeed, even if we were to agree that claim 1 is directed to an ineligible abstract idea under step one, the claim is eligible under step two because it contains a sufficient ‘inventive concept.’

Something More: Yes

In other words, this claim entails an unconventional technological solution (enhancing data in a distributed fashion) to a technological problem (massive record flows which previously required massive databases). The solution requires arguably generic components, including network devices and “gatherers” which “gather” information. However, the claim’s enhancing limitation necessarily requires that these generic components operate in an unconventional manner to achieve an improvement in computer functionality.

The court then continues to compare and contrast the claims with those at issue in BASCOM, DDR Holdings, Digitech, Content Extraction, and In re TLI Commc’ns.