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Motio, Inc. v. BSP Software LLC

Representative Claim

  1. In a general purpose computer, a method for providing automatic version control to a business intelligence system, comprising:

creating an initial version of a business intelligence artifact in the business intelligence system, wherein the business intelligence artifact is a user-authored object that produces output when the business intelligence artifact is executed in the business intelligence system, and wherein the business intelligence artifact is selected from the group consisting of: a report specification and an analysis cube;

providing an automated agent that interfaces with the business intelligence system to provide automated version control to the business intelligence artifact; the automated agent independently performing the steps of:

automatically storing the initial version of the business intelligence artifact with a version control system;

detecting a request to the business intelligence system to modify the initial version of the business intelligence artifact to create a subsequent version of the business intelligence artifact that includes the requested modification; and

automatically storing the subsequent version of the business intelligence artifact in the version control system.

Posture:

Motion for Summary Judgment.

Abstract Idea: No

The Court found that claim 1 is directed to the abstract idea of maintaining versions of electronic documents.  Here, the Court stated, “[w]hile the claims are directed toward a particular technological environment—a computer—a particular type of electronic document—report specifications and analysis cubes—and an application in business intelligence systems, this does not change the underlying abstract idea of maintaining versions, or ―version control, of electronic documents.”  Indeed, the Patent Owner essentially conceded this point and reserved the weight of its argument for step two of the Mayo/Alice test.

Something More: N/A

Although claim 1 was indisputably determined to be directed to an abstract idea, the Court found that the claim as a whole included sufficient elements to transform the nature of the claim into patent-eligible subject matter.  In particular, the Court focused on the feature of “providing an ‘automated agent’‖ that interfaces with the business intelligence system to provide version control to the business intelligence artifact.”  Here, the Court agreed with the Patent Owner that the claimed “automated agent” amounted to “something more,” stating:

“The claims at issue, however, do not merely automate a purely conventional technique or abstract idea, but rather provide an ‘automated agent.’ Moreover, in the Court‘s view the claims are not shown to amount to ‘significantly more’ simply because the automated agent operates ‘automatically.’

……….

It is the provision of this automated agent to solve the problem of a business intelligence system lacking native version control that amounts to significantly more than a patent on the idea of maintaining versions of electronic documents itself.

……….

The claims provide, and the Court‘s construction of the term ‘automated agent’ reflects, that the automated agent is ‘software that interfaces with the business intelligence system,’ making clear the distinct nature of the automated agent (Dkt. #145 at p. 13). Though the parties disagree about the level of externality the claims require, the Court finds that it is sufficient to describe the automated agent as software distinct from the business intelligence system. The claims describe an invention that serves as an addition to a business intelligence system rather than claiming a monopoly on all version control systems, particularly version control native to a business intelligence system.

The Court further supported its positive determination in step two of the Mayo/Alice test by asserting the logic of DDR Holdings, stating:

Plaintiff argues, and the Court agrees, that as in DDR Holdings, the invention does not simply use a computer to automate was done previously, but rather improves upon what was previously done with computers, solving a computer specific problem (Dkt. #170 at p. 12). The patent-at-issue expands the functionality of existing computer software, local or on a computer network, by addressing a problem specific to the realm of computers.

……….

Moreover, the ’678 Patent does not claim version control generally, but rather a specific method, using an ‘automated agent’ distinct from a business intelligence system to improve the functionality of a business intelligence system. Therefore, the claims describe a particular method of providing one type of version control that does not preempt every application of the idea of maintaining versions of electronic documents or even all methods of version control in a business intelligence system.”