Generic components working in an unconventional fashion to solve a particular technological problem is patent-eligible under § 101. Here, for example, a network accounting system that used only conventional components (e.g., “gatherers”) was found to be patent-eligible because it provided 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 … [but] requires that these generic components operate in an unconventional manner to achieve an improvement in computer functionality.” This would be a good case to consult and cite in response to a subject matter eligibility rejection for a claimed arrangement of otherwise generic computer components.
Background / Facts: The patents being asserted here are directed to enhancing the ability of network service providers to account for and bill for network communications across a large number of devices. The claims recite computer code for “correlating [a] first network accounting record with accounting information available from a second source” and using it “to enhance the first network accounting record.” The specification explains how this “enhancing” is dependent upon the invention’s distributed architecture, which is touted as a critical advancement over the prior art.
Issue(s): Whether the claims are patent-eligible under § 101.
Holding(s): Yes. “[T]his 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. … It is narrowly drawn to not preempt any and all generic enhancement of data in a similar system, and does not merely combine the components in a generic manner, but instead purposefully arranges the components in a distributed architecture to achieve a technological solution to a technological problem specific to computer networks.”