On September 5, 2013, in Accenture Global Services v. Guidewire Software, Inc., the US Court of Appeals for the Federal Circuit issued an opinion affirming the US District Court for the District of Delaware's grant of summary judgment holding that all claims of Accenture's US Patent 7,013,284 ('284 patent) directed to a computer-aided system were invalid under 35 U.S.C. § 101 because they recited patent-ineligible subject matter. This case highlights the Federal Circuit's continuing efforts, as witnessed in CLS Bank Int'l v. Alice Corp. and Ultramercial Inc. v. Hulu LLC, to apply workable standards for determining the patent subject matter eligibility of computer-aided process and system claims.

Plaintiff Accenture's '284 patent claimed computer-aided systems and methods for generating and organizing insurance-related tasks involving insurance transactions, policies and claims. The patent contained two independent claims, claim 1 (a system claim) and claim 8 (a method claim). Both claims expressly or impliedly disclosed the use of the same software system components, like an insurance transaction database and server and client components, and the same database fields.

Accenture sued Guidewire for alleged infringement of the '284 patent. Guidewire moved for summary judgment alleging that the '284 patent was invalid under Section 101 of the Patent Act because it claimed ineligible patent subject matter. The district court granted Guidewire's motion for summary judgment, ruling all of the '284 patent claims patent ineligible because they were drawn to abstract ideas. The district court held method claim 8 patent-ineligible because:

The district court similarly found system claim 1 ineligible because the claim language mirrored the language of claim 8 and, like claim 8, failed to include any limitations restricting the claim to a specific application of the claim's underlying abstract idea. Accenture appealed the district court's judgment solely with respect to its system claims (1 through 7). The parties's briefings and arguments focused only on the independent system and method claims (claim 1 and 8, respectively), a fact that the Federal Circuit seized upon to conclude that the eligibility of the dependent system claims (claims 2 through 7) depended on the patent eligibility of claim 1.

On appeal, the Federal Circuit, in a split decision, affirmed the district court's grant of Guideline's motion for summary judgment. The court followed the two-step process for analyzing patent eligibility under CLS Bank Int'l v. Alice Corp. as guided by the Supreme Court's decision in Mayo Collaborate Servs. v. Prometheus Labs., Inc.. This process requires the court to:

Relying on the plurality opinion in CLS Bank, the court ruled that, because Accenture's '284 patent system claims so closely track its method claims and merely recite a system that implements the method claims on a general purpose computer without disclosing any meaningful limitations, these system and method claims must rise or fall together. The Federal Circuit then further concluded that, because Accenture failed to appeal the district court judgment holding the '284 patent method claims invalid, the system claims must necessarily follow suit.

However, the court did not confine itself to the rather mechanical analysis, but rather, proceeded to evaluate Accenture's system claims both individually and in comparison with the invalidated method claims. Based on this analysis the majority concluded that:

The court therefore affirmed the district court's holding that the system claims were invalid as directed to patent ineligible subject matter under Section 101.

This case demonstrates the Federal Circuit's continuing uncertainty concerning and evolving formulation of the law of patent subject matter eligibility as applied to computer-aided system and method claims.