Accenture Global Servs., GMBH v. Guidewire Software, Inc.

Where a system claim only limits the environment where the method step are implemented, it does not offer a meaningful limitation.

Opinion (Lourie): Accenture Global Services; GMBH ("Accenture") holds a patent on a computer program for handling insurance-related tasks. In 2007, it sued Guidewire Software, Inc. ("Guidewire") alleging that Guidewire infringed its patent. Guidewire defended by arguing the patent was invalid because it claimed non-patentable subject matter, specifically it argued that several of the patent’s claims failed the machine-or-transformation test. Guidewire moved for summary judgment. The District Court for Delaware granted the motion, finding that the claims were directed toward organizing data, not to specific devices or systems, and that limiting the claims to the insurance industry did not sufficiently limit the claims. Specifically, it held the method claim was invalid because it was not restricted to a concrete application of an abstract idea, and it held the system claim invalid because it mirrored the language of the method claim. Accenture appealed the district court’s decision for all claims except the method claim. System claims that mirror method claims and that have the same meaningful limitations normally rise and fall together. Where a system claim only limits the environment where the method step are implemented, it does not offer a meaningful limitation. Because the system claim and the method claim in Accenture’s patent contained few differences, but implemented the same process. Because Accenture did not appeal the invalidation of its method claim, the Federal Circuit affirmed the invalidation of the system claim because it did not provide sufficient limitations to distinguish its abstract idea from the patent ineligible method claim. Even if the method claim was not considered, however, the Federal Circuit held the system claim was still invalid because it did not contain meaningful limitations that restricted the claim’s application rather than claiming an abstract idea. Accordingly, the Federal Circuit AFFIRMED the district court’s grant of summary judgement.