Accenture Global Services v. Guidewire Software, Inc.
728 F.3d 1336
| Fed. Cir. | 2013Background
- Accenture appeals a district court summary judgment that all '284 patent claims are invalid under §101.
- The district court held both method claims (8 and related) and the system claim (1) ineligible, finding them directed to abstract ideas with no meaningful limitations.
- The '284 patent discloses software components for handling insurance-related tasks, including an insurance transaction database, a task library, a client component, and a server with an event processor, a task engine, and a task assistant.
- Claims 1 and 8 both recite generating tasks in an insurance organization, with substantially overlapping components and structures.
- Accenture challenged the eligibility of the system claim 1, arguing it implements a concrete computer-structured program.
- The court applied the CLS Bank Mayo framework, concluding the claims are patent-ineligible for failing to provide meaningful limitations beyond an abstract concept.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Are system claims 1-7 §101 patent-ineligible? | Accenture maintains system claims add meaningful computer-based limitations. | Guidewire contends claims mirror the ineligible abstract idea of the method. | Yes; system claims are invalid under §101. |
| Do system claims have meaningful limitations beyond the unappealed method claims? | Accenture argues the claimed hardware and databases provide distinct limits. | Guidewire argues limitations are insubstantial and merely implement the abstract idea on a computer. | No; system claims lack meaningful limitations and rise/fall with the method claims. |
Key Cases Cited
- CLS Bank Int’l v. Alice Corp., 717 F.3d 1269 (Fed. Cir. 2013) (two-step framework for §101, abstract idea preemption analysis; system and method claims often rise/fall together when closely tied to same abstract idea)
- Bancorp Servs., LLC v. Sun Life Assurance Co. of Can., 687 F.3d 1266 (Fed. Cir. 2012) (patent eligibility of software/system claims judged by their meaningful limitations)
- In re Bilski, 545 F.3d 943 (Fed. Cir. 2008) (machine-or-transformation test as a prior framework for §101 analysis (en banc))
- Parker v. Flook, 437 U.S. 584 (U.S. 1978) (abstract ideas and restrictions on patentees beyond mere implementation)
- Diehr, 450 U.S. 175 (U.S. 1981) (post-solution activity and limitations to avoid preemption of abstract ideas)
- Mayo Collaborative Servs. v. Prometheus Labs., 132 S. Ct. 1289 (U.S. 2012) (two-step Mayo framework for §101 analysis; abstract ideas and preemption)
- Ultramercial, Inc. v. Hulu, LLC, 722 F.3d 1335 (Fed. Cir. 2013) (distinguishes posture-based considerations; claims must show meaningful limitations)