An Eastern District of Texas judge upheld the patentability of a software patent related to business intelligence. The claims of the patent were directed to a method of providing an automatic version control to a business intelligence system. U.S. District Judge Amos L. Mazzant held that even though the asserted claims of software company Motio Inc.’s U.S. Patent Number 8,285,678 are for the abstract idea of maintaining versions of electronic documents, the claims nonetheless survive Alice because the patent contains inventive concepts.
The court held that the claims describe an “automated agent” that does not simply use a computer to automate prior concepts; instead it solves technologically specific problems. Specifically, Judge Mazzant wrote that the claims survive an Alice challenge because “[i]t is the provision of this automated agent to solve the problem of a business intelligence system lacking local control that amounts to significantly more than a patent on the idea of maintaining versions of electronic documents itself…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.... Moreover, the [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.”
Motio, Inc. v. BSP Software LLC et al, 4-12-cv-00647 (E.D. Tex. January 4, 2016, Order) (Mazzant, J.)