The court went on to find that the asserted claims for each of the four patents failed step one of the Alice analysis as they were directed to four different abstract ideas related the same system, namely, “correlating two network accounting records to enhance the first record;” “using a database to compile and report on network usage information;” “generat[ing] a single record reflecting multiple services;” and “reporting on the collection of network usage information from a plurality of network devices.” The court additionally found that none of the asserted claims added anything more to these “abstract ideas” than generic computer hardware, so they also failed Alice’sstep two. Notably, the court declined to consider whether or not the process as a whole was novel in making the determination. “A person may have invented an entirely new and useful advance, but if the patent claims sweep too broadly, or only claim the idea that was achieved rather than implementation of the idea, then § 101 directs that the patent is invalid.” Thus, even if the idea(s) that grounded the claimed systems and methods were novel, the claims were too broad and claimed too much to be considered patent eligible.
Amdocs (Israel) Ltd. v. Openet Telecom, Inc., No. 1:10CV910 LMB/TRJ, 2014 WL 5430956 (E.D. Va. Oct. 24, 2014) (Judge Leonie M. Brinkema).