Case Law Accenture Global Servs. v. Guidewire Software, Inc.

Accenture Global Servs. v. Guidewire Software, Inc.

Document Cited Authorities (15) Cited in (766) Related (5)

OPINION TEXT STARTS HERE

J. Michael Jakes, Finnegan, Henderson, Farabow, Garrett & Dunner, LLP, of Washington, DC, argued for plaintiffs-appellants. With him on the brief were Erika H. Arner and Justin R. Lowery.

Mark A. Lemley, Durie Tangri, LLP, of San Francisco, CA, argued for defendant-appellee. With him on the brief was Daralyn J. Durie.

Before RADER, Chief Judge, LOURIE and REYNA, Circuit Judges.

Opinion for the court filed by Circuit Judge LOURIE.

Dissenting opinion filed by Chief Judge RADER.

LOURIE, Circuit Judge.

Accenture Global Services, GmbH and Accenture, LLP (Accenture) appeal from the grant of summary judgment by the United States District Court for the District of Delaware holding that all claims of U.S. Patent 7,013,284 (the “'284 patent”) are invalid under 35 U.S.C. § 101. Accenture Global Servs., GmbH v. Guidewire Software, Inc., 800 F.Supp.2d 613, 621–22 (D.Del.2011). Accenture appealed that determination only as to claims 1–7, directed to a system for generating tasks to be performed in an insurance organization, but did not appeal the similar method claims 8–22. As described more fully below, we affirm the district court's judgment and hold that the system claims before us recite patent-ineligible subject matter.

Background
I. The '284 Patent

The '284 patent describes [a] computer program ... for handling insurance-related tasks.” '284 patent col. 3 ll. 23–25. The patent discloses various software components of the program, including a “data component that stores, retrieves and manipulates data” and a client component that “transmits and receives data to/from the data component.” Id. col. 3 ll. 25–29. The client component also includes a business component that “serves as a data cache and includes logic for manipulating the data.” Id. col. 3 ll. 29–31. The program further describes a controller component to handle program events and an adapter component to interface with a data repository. Id. col. 3 ll. 31–35.

The specification contains detailed descriptions of the various software components, see id. col. 8–107, including many of the functions those components utilize and how those components interact. The patent contains two independent claims, both of which require generating and organizing insurance-related tasks.

Claim 1 is a claim to a system for generating tasks to be performed in an insurance organization. The system stores information on insurance transactions in a database. Upon the occurrence of an event, the system determines what tasks need to be accomplished for that transaction and assigns those tasks to various authorized individuals to complete them. In order to accomplish this, the claimed system includes an insurance transaction database, a task library database, a client component for accessing the insurance transaction database, and a server component that interacts with the software components and controls an event processor, which watches for events and sends alerts to a task engine that determines the next tasks to be completed.

Claim 1 is reproduced below:

A system for generating tasks to be performed in an insurance organization, the system comprising:

an insurance transaction database for storing information related to an insurance transaction, the insurance transaction database comprising a claim folder containing the information related to the insurance transaction decomposed into a plurality of levels from the group comprising a policy level, a claim level, a participant level and a line level, wherein the plurality of levels reflects a policy, the information related to the insurance transaction, claimants and an insured person in a structured format;

a task library database for storing rules for determining tasks to be completed upon an occurrence of an event;

a client component in communication with the insurance transaction database configured for providing information relating to the insurance transaction, said client component enabling access by an assigned claim handler to a plurality of tasks that achieve an insurance related goal upon completion; and

a server component in communication with the client component, the transaction database and the task library database, the server component including an event processor, a task engine and a task assistant;

wherein the event processor is triggered by application events associated with a change in the information, and sends an event trigger to the task engine; wherein in response to the event trigger, the task engine identifies rules in the task library database associated with the event and applies the information to the identified rules to determine the tasks to be completed, and populates on a task assistant the determined tasks to be completed, wherein the task assistant transmits the determined tasks to the client component.

Id. col. 107 ll. 25–59.

Claim 8 claims a method for generating tasks to be performed in an insurance organization. The method takes an insurance transaction and applies rules to that transaction to determine tasks to be completed. These tasks are made accessible to authorized individuals who then complete the task.

Claim 8 reads as follows:

An automated method for generating tasks to be performed in an insurance organization, the method comprising:

transmitting information related to an insurance transaction;

determining characteristics of the information related to the insurance transaction;

applying the characteristics of the information related to the insurance transaction to rules to determine a task to be completed, wherein an event processor interacts with an insurance transaction database containing information related to an insurance transaction decomposed into a plurality of levels from the group comprising a policy level, a claim level, a participant level and a line level, wherein the plurality of levels reflects a policy, the information related to the insurance transaction, claimants and an insured person in a structured format;

transmitting the determined task to a task assistant accessible by an assigned claim handler, wherein said client component displays the determined task;

allowing an authorized user to edit and perform the determined task and to update the information related to the insurance transaction in accordance with the determined task;

storing the updated information related to the insurance transaction; and

generating a historical record of the completed task.

Id. col. 108 ll. 12–41.

Both claim 1 and claim 8 disclose aspects of “generating tasks to be performed in an insurance organization.” Claim 1 and claim 8 further include many of the same software components. They both include an insurance transaction database, which contains a policy level, a claim level, a participant level, and a line level. Further, both the system and the method claims require a client component for allowing an assigned claim handler to access tasks, an event processor, and a task assistant for scheduling and monitoring those tasks.

II. District Court Proceedings

On December 18, 2007, Accenture filed suit against Guidewire alleging infringement of the '284 patent as well as asserting various state law claims. Accenture Global Servs., GmbH v. Guidewire Software, Inc., 691 F.Supp.2d 577, 579 (D.Del.2010). Guidewire asserted multiple affirmative defenses including that the patent was invalid under 35 U.S.C. § 101 for claiming non-patent-eligible subject matter. Guidewire moved for summary judgment, asserting that the patent was invalid because claims 1, 8, and their related dependent claims did not meet the machine-or-transformation test articulated in our decision in In re Bilski, 545 F.3d 943 (Fed.Cir.2008) (en banc) aff'd on other grounds sub nom. Bilski v. Kappos, 560 U.S. ––––, 130 S.Ct. 3218, 177 L.Ed.2d 792 (2010). Because the Supreme Court had by then granted certiorari in Bilski, but had not yet issued its own decision, the district court denied the motion for summary judgment without prejudice, allowing Guidewire to renew the motion after a Supreme Court decision issued. Accenture Global Servs., GmbH v. Guidewire Software, Inc., No. 07–826–SLR, 2010 WL 723003 (D.Del. Feb. 26, 2010), ECF No. 478.

After the Supreme Court issued its decision in Bilski, Guidewire renewed its motion for summary judgment, arguing that the '284 patent is drawn to abstract ideas that fail the machine-or-transformation test. On May 31, 2011, after briefing from both sides, the district court granted Guidewire's motion for summary judgment, finding the claims of the '284 patent ineligible because the claims are drawn to abstract ideas. Accenture, 800 F.Supp.2d at 621–22.

The district court held that the '284 patent was “directed to concepts for organizing data rather than to specific devices or systems, and limiting the claims to the insurance industry does not specify the claims sufficiently to allow for their survival.” Id. at 621 (citing Bilski, 130 S.Ct. at 3231;Parker v. Flook, 437 U.S. 584, 589–90, 98 S.Ct. 2522, 57 L.Ed.2d 451 (1978)). Specifically, the court held that method claim 8 is patent-ineligible because none of the claim limitations restrict claim 8 to a concrete application of the abstract idea, and that the dependent method claims only add “limitations regarding potential claim information categories.” Id. at 621. The district court found that system claim 1 is patent-ineligible because the claim language “mirrors the language of the method disclosed in claim 8.” Id. Those conclusions, “in conjunction with the court's prior conclusion that the ['284 patent fails] the machine or transformation test” led the court to grant the motion for summary judgment of invalidity under § 101.

Accordingly, the district court entered final...

5 cases
Document | U.S. District Court — District of Delaware – 2016
Device Enhancement LLC. v. Amazon.com, Inc.
"... ... at 611–12, 130 S.Ct. 3218 and Mayo Collaborative Servs. v. Prometheus Labs., Inc. , 566 U.S. 66, 132 S.Ct. 1289, ... May 12, 2016), addressed claims directed to software and concluded that such claims were not "inherently ... the claims in Alice , Ultramercial, buySAFE, Accenture , and Bancorp that were found to be "directed to" little ... , 765 F.3d 1350, 1355 (Fed.Cir.2014) ; Accenture Global Servs., GmbH v. Guidewire Software, Inc. , 728 F.3d 1336, ... "
Document | U.S. District Court — Northern District of Illinois – 2018
Chamberlain Grp., Inc. v. Techtronic Indus. Co.
"... ... v. Cable & Wireless Internet Servs., Inc., 344 F.3d 1186, 1192 (Fed. Cir. 2003) (quoting ... at 2354 ; Accenture Global Servs., GmbH v. Guidewire Software, Inc., 728 F.3d ... "
Document | U.S. Court of Appeals — Federal Circuit – 2016
Amdocs (Israel) Ltd. v. Openet Telecom, Inc.
"... ... Id. at 5:35–39. Gatherers can be hardware and software installed on the same network segment as a network device ... at 2355 (following Mayo Collaborative Servs. v. Prometheus Labs., Inc. , ––– U.S. ––––, ... that recites generic computer parts.”) (citing Accenture Global Servs., GmbH v. Guidewire Software, Inc. , 728 F.3d ... "
Document | U.S. District Court — Western District of Texas – 2015
Affinity Labs of Tex., LLC v. DirecTV, LLC
"... ... , LLC, Turner Digital Basketball Services, Inc., NHL Enterprises, L.P., NHL Enterprises, Inc ... exclusively to none." Mayo Collaborative Servs. v. Prometheus Labs., ––– U.S ... v. Alfresco Software Ltd, No. 13–CV–04843–JD, 2014 WL 4684429, ... underlying factual issues." See Accenture Global Servs., GmbH v. Guidewire Software, Inc., ... "
Document | U.S. District Court — District of Delaware – 2019
British Telecommunications PLC v. Iac/Interactive Corp
"... ... IAC/INTERACTIVECORP, Match Group, Inc., Match Group, LLC, and Vimeo, Inc., Defendants ... (quoting Mayo Collaborative Servs. v. Prometheus Labs., Inc. 566 U.S. 66, 72–73, ... Cir. 2016) ; Accenture Glob. Servs., GmbH v. Guidewire Software, Inc. , ... "

Try vLex and Vincent AI for free

Start a free trial
5 books and journal articles
Document | Núm. 104-5, July 2019 – 2019
PTO Panel Stacking: Unblessed by the Federal Circuit and Likely Unlawful
"...types of claims “generally rise or fall together” under subject-matter eligibility analysis. Accenture Glob. Servs., GmbH v. Guidewire Software, Inc., 728 F.3d 1336, 1341–42 (Fed. Cir. 2013) (discussing opinions in CLS Bank Int’l ). 86. Gregg v. Georgia, 428 U.S. 153 (1976). 87 . Id. at 158..."
Document | CHAPTER 3 Patent-Eligible Subject Matter
Chapter §3.02 Processes Within §101
"...F.3d 1314 (Fed. Cir. 2016)], 811 F.3d at 1325 (emphasis in original) (quoting Accenture Global Servs., GmbH v. Guidewire Software, Inc., 728 F.3d 1336, 1341 (Fed. Cir. 2013)). And the Supreme Court recognized that in making the § 101 determination, the inquiry "might sometimes overlap" with..."
Document | The technology transfer law handbook – 2014
Patenting Software
"...abstract ideas broadly and rules claimed subject matter patent‑ineligible under 35 U.S.C. 57. Id. at 1346. 58. Id. at 1347. 59. 728 F.3d 1336 (Fed. Cir. 2013). PATENTING SOFTWARE § 101. That is very clear from the majority opinion in Accenture Global Services , which reduced the claimed sys..."
Document | Núm. 39-1, March 2014
Patentable Subject Matter, Abstract Ideas, Business Methods, and the Patent Eligibility Trilogy
"...437 U.S. at 586.108. In fact, the Federal Circuit's recent decision in Accenture Global Services, GMBH v. Guidewire Software, Inc., 728 F.3d 1336 (Fed. Cir. 2013), indicates that the separate factions remain strong in their convictions as judges Laurie and Reyna found the system claims inel..."
Document | Núm. 39-1, March 2014
Case Comments
"...on rules completed upon the occurrence of an event. judge Rader dissented. Accenture Global Servs. GmbH v. Guidewire Software, Inc., 728 F.3d 1336, 108 U.S.P.Q2d 1173 (Fed. Cir. 2013).PATENTS - TERM EXTENSION Under 35 U.S.C. § 154(b)(1)(B) the term of a patent is extended to add one day for..."

Try vLex and Vincent AI for free

Start a free trial
5 firm's commentaries
Document | JD Supra United States – 2017
Shearman & Sterling’s Digest on Federal Circuit Jurisprudence Concerning the “Abstract Idea” Exception to 35 U.S.C. § 101
"...so, the Federal Circuit has ignored the fact that the parties in Alice stipulated to representative claims. In Accenture Global Servs., GmbH v. Guidewire Software, Inc., the court held that a district court decision on patent-ineligibility of system claims must be affirmed, because those cl..."
Document | Mondaq United States – 2016
Software Patents: History And Strategies (Pt. I – History)
"...SmartGene, Inc. v Advanced Biological Labs., 555 Fed. Appx. 950 (Fed. Cir. 2014). Accenture Global Services, GmbH v. Guidewire Software, 728 F.3d 1336 (Fed. Cir. 2014); PerkinElmer Inc. v Intema Ltd., 496 Fed. Appx. 65 (Fed. Cir. 2012); Bancorp Services v. Sun Life, 687 F.3d 1266, 1278 (Fed..."
Document | JD Supra United States – 2017
Can Juries Decide Patent Eligibility Under 35 U.S.C. § 101?
"...Grader, Inc. v. First Choice Loan Servs. Inc., 811 F.3d 1314, 1325–26 (Fed. Cir. 2016) (quoting Accenture Global Servs., GmbH v. Guidewire Software, Inc., 728 F.3d 1336, 1341 (Fed. Cir. 2013)) (holding that § 101 was properly decided at mary judgment despite “dueling expert testimony” where..."
Document | Mondaq United States – 2015
USPTO Issues Newly Updated Guidance On Subject Matter Eligibility That Further Clarifies Examination Standards Under 35 U.S.C. §101 In Light Of Alice V. CLS Bank
"...4 In re Roslin Inst. Of Edinburgh, Scotland, 750 F.3d 1333, 1335 (2014); Accenture Global Services, GmbH v. Guidewire Software, 728 F.3d 1336, 1340‐41 (Fed. Cir. 2013); Fort Properties, Inc. v. American Master Lease LLC, 671 F.3d 1317, 1320 (Fed. Cir. 2012); Cybersource, 654 F.3d at 1369; S..."
Document | JD Supra United States – 2014
Of Pies and Patent Eligibility: A Dialogue
"...preempt anything beyond the specific claims, let alone a broad and undefined concept” Accenture Global Services v. Guidewire Software, Inc. 728 F.3d 1336, 1348 (Fed. Cir. 2013) (Rader, C.J., dissenting). Unlike some policy-based approaches, objective preemption is a methodology that is trul..."

Try vLex and Vincent AI for free

Start a free trial

Experience vLex's unparalleled legal AI

Access millions of documents and let Vincent AI power your research, drafting, and document analysis — all in one platform.

Start a free trial

Start Your 3-day Free Trial of vLex and Vincent AI, Your Precision-Engineered Legal Assistant

  • Access comprehensive legal content with no limitations across vLex's unparalleled global legal database

  • Build stronger arguments with verified citations and CERT citator that tracks case history and precedential strength

  • Transform your legal research from hours to minutes with Vincent AI's intelligent search and analysis capabilities

  • Elevate your practice by focusing your expertise where it matters most while Vincent handles the heavy lifting

vLex
5 books and journal articles
Document | Núm. 104-5, July 2019 – 2019
PTO Panel Stacking: Unblessed by the Federal Circuit and Likely Unlawful
"...types of claims “generally rise or fall together” under subject-matter eligibility analysis. Accenture Glob. Servs., GmbH v. Guidewire Software, Inc., 728 F.3d 1336, 1341–42 (Fed. Cir. 2013) (discussing opinions in CLS Bank Int’l ). 86. Gregg v. Georgia, 428 U.S. 153 (1976). 87 . Id. at 158..."
Document | CHAPTER 3 Patent-Eligible Subject Matter
Chapter §3.02 Processes Within §101
"...F.3d 1314 (Fed. Cir. 2016)], 811 F.3d at 1325 (emphasis in original) (quoting Accenture Global Servs., GmbH v. Guidewire Software, Inc., 728 F.3d 1336, 1341 (Fed. Cir. 2013)). And the Supreme Court recognized that in making the § 101 determination, the inquiry "might sometimes overlap" with..."
Document | The technology transfer law handbook – 2014
Patenting Software
"...abstract ideas broadly and rules claimed subject matter patent‑ineligible under 35 U.S.C. 57. Id. at 1346. 58. Id. at 1347. 59. 728 F.3d 1336 (Fed. Cir. 2013). PATENTING SOFTWARE § 101. That is very clear from the majority opinion in Accenture Global Services , which reduced the claimed sys..."
Document | Núm. 39-1, March 2014
Patentable Subject Matter, Abstract Ideas, Business Methods, and the Patent Eligibility Trilogy
"...437 U.S. at 586.108. In fact, the Federal Circuit's recent decision in Accenture Global Services, GMBH v. Guidewire Software, Inc., 728 F.3d 1336 (Fed. Cir. 2013), indicates that the separate factions remain strong in their convictions as judges Laurie and Reyna found the system claims inel..."
Document | Núm. 39-1, March 2014
Case Comments
"...on rules completed upon the occurrence of an event. judge Rader dissented. Accenture Global Servs. GmbH v. Guidewire Software, Inc., 728 F.3d 1336, 108 U.S.P.Q2d 1173 (Fed. Cir. 2013).PATENTS - TERM EXTENSION Under 35 U.S.C. § 154(b)(1)(B) the term of a patent is extended to add one day for..."

Try vLex and Vincent AI for free

Start a free trial

Start Your 3-day Free Trial of vLex and Vincent AI, Your Precision-Engineered Legal Assistant

  • Access comprehensive legal content with no limitations across vLex's unparalleled global legal database

  • Build stronger arguments with verified citations and CERT citator that tracks case history and precedential strength

  • Transform your legal research from hours to minutes with Vincent AI's intelligent search and analysis capabilities

  • Elevate your practice by focusing your expertise where it matters most while Vincent handles the heavy lifting

vLex
5 cases
Document | U.S. District Court — District of Delaware – 2016
Device Enhancement LLC. v. Amazon.com, Inc.
"... ... at 611–12, 130 S.Ct. 3218 and Mayo Collaborative Servs. v. Prometheus Labs., Inc. , 566 U.S. 66, 132 S.Ct. 1289, ... May 12, 2016), addressed claims directed to software and concluded that such claims were not "inherently ... the claims in Alice , Ultramercial, buySAFE, Accenture , and Bancorp that were found to be "directed to" little ... , 765 F.3d 1350, 1355 (Fed.Cir.2014) ; Accenture Global Servs., GmbH v. Guidewire Software, Inc. , 728 F.3d 1336, ... "
Document | U.S. District Court — Northern District of Illinois – 2018
Chamberlain Grp., Inc. v. Techtronic Indus. Co.
"... ... v. Cable & Wireless Internet Servs., Inc., 344 F.3d 1186, 1192 (Fed. Cir. 2003) (quoting ... at 2354 ; Accenture Global Servs., GmbH v. Guidewire Software, Inc., 728 F.3d ... "
Document | U.S. Court of Appeals — Federal Circuit – 2016
Amdocs (Israel) Ltd. v. Openet Telecom, Inc.
"... ... Id. at 5:35–39. Gatherers can be hardware and software installed on the same network segment as a network device ... at 2355 (following Mayo Collaborative Servs. v. Prometheus Labs., Inc. , ––– U.S. ––––, ... that recites generic computer parts.”) (citing Accenture Global Servs., GmbH v. Guidewire Software, Inc. , 728 F.3d ... "
Document | U.S. District Court — Western District of Texas – 2015
Affinity Labs of Tex., LLC v. DirecTV, LLC
"... ... , LLC, Turner Digital Basketball Services, Inc., NHL Enterprises, L.P., NHL Enterprises, Inc ... exclusively to none." Mayo Collaborative Servs. v. Prometheus Labs., ––– U.S ... v. Alfresco Software Ltd, No. 13–CV–04843–JD, 2014 WL 4684429, ... underlying factual issues." See Accenture Global Servs., GmbH v. Guidewire Software, Inc., ... "
Document | U.S. District Court — District of Delaware – 2019
British Telecommunications PLC v. Iac/Interactive Corp
"... ... IAC/INTERACTIVECORP, Match Group, Inc., Match Group, LLC, and Vimeo, Inc., Defendants ... (quoting Mayo Collaborative Servs. v. Prometheus Labs., Inc. 566 U.S. 66, 72–73, ... Cir. 2016) ; Accenture Glob. Servs., GmbH v. Guidewire Software, Inc. , ... "

Try vLex and Vincent AI for free

Start a free trial

Start Your 3-day Free Trial of vLex and Vincent AI, Your Precision-Engineered Legal Assistant

  • Access comprehensive legal content with no limitations across vLex's unparalleled global legal database

  • Build stronger arguments with verified citations and CERT citator that tracks case history and precedential strength

  • Transform your legal research from hours to minutes with Vincent AI's intelligent search and analysis capabilities

  • Elevate your practice by focusing your expertise where it matters most while Vincent handles the heavy lifting

vLex

Start Your 3-day Free Trial of vLex and Vincent AI, Your Precision-Engineered Legal Assistant

  • Access comprehensive legal content with no limitations across vLex's unparalleled global legal database

  • Build stronger arguments with verified citations and CERT citator that tracks case history and precedential strength

  • Transform your legal research from hours to minutes with Vincent AI's intelligent search and analysis capabilities

  • Elevate your practice by focusing your expertise where it matters most while Vincent handles the heavy lifting

vLex
5 firm's commentaries
Document | JD Supra United States – 2017
Shearman & Sterling’s Digest on Federal Circuit Jurisprudence Concerning the “Abstract Idea” Exception to 35 U.S.C. § 101
"...so, the Federal Circuit has ignored the fact that the parties in Alice stipulated to representative claims. In Accenture Global Servs., GmbH v. Guidewire Software, Inc., the court held that a district court decision on patent-ineligibility of system claims must be affirmed, because those cl..."
Document | Mondaq United States – 2016
Software Patents: History And Strategies (Pt. I – History)
"...SmartGene, Inc. v Advanced Biological Labs., 555 Fed. Appx. 950 (Fed. Cir. 2014). Accenture Global Services, GmbH v. Guidewire Software, 728 F.3d 1336 (Fed. Cir. 2014); PerkinElmer Inc. v Intema Ltd., 496 Fed. Appx. 65 (Fed. Cir. 2012); Bancorp Services v. Sun Life, 687 F.3d 1266, 1278 (Fed..."
Document | JD Supra United States – 2017
Can Juries Decide Patent Eligibility Under 35 U.S.C. § 101?
"...Grader, Inc. v. First Choice Loan Servs. Inc., 811 F.3d 1314, 1325–26 (Fed. Cir. 2016) (quoting Accenture Global Servs., GmbH v. Guidewire Software, Inc., 728 F.3d 1336, 1341 (Fed. Cir. 2013)) (holding that § 101 was properly decided at mary judgment despite “dueling expert testimony” where..."
Document | Mondaq United States – 2015
USPTO Issues Newly Updated Guidance On Subject Matter Eligibility That Further Clarifies Examination Standards Under 35 U.S.C. §101 In Light Of Alice V. CLS Bank
"...4 In re Roslin Inst. Of Edinburgh, Scotland, 750 F.3d 1333, 1335 (2014); Accenture Global Services, GmbH v. Guidewire Software, 728 F.3d 1336, 1340‐41 (Fed. Cir. 2013); Fort Properties, Inc. v. American Master Lease LLC, 671 F.3d 1317, 1320 (Fed. Cir. 2012); Cybersource, 654 F.3d at 1369; S..."
Document | JD Supra United States – 2014
Of Pies and Patent Eligibility: A Dialogue
"...preempt anything beyond the specific claims, let alone a broad and undefined concept” Accenture Global Services v. Guidewire Software, Inc. 728 F.3d 1336, 1348 (Fed. Cir. 2013) (Rader, C.J., dissenting). Unlike some policy-based approaches, objective preemption is a methodology that is trul..."

Try vLex and Vincent AI for free

Start a free trial