Object Oriented Software-Relational Database Interface Patent Not Invalid Under 35 U.S.C. § 101

Following remand, the court denied defendant's motion for summary judgment that plaintiff's database interface patent was invalid for lack of patentable subject matter and found that the patent was not directed toward an abstract idea. "The Federal Circuit has described the [patent-in-suit] as . . . 'directed to interfacing an object oriented software application to access data stored in a relational database. . . . [T]he . . . patent discloses creating 'interface objects' that act as intermediaries between the object oriented application and the relational database.' . . . [W]hen read as a whole, the patent here does not recite a computer as a post-solution limitation or a specific application of a more generic abstract idea. Rather, the [patent] is directed at solving a problem that specifically arises in the realm of computing; indeed, object-oriented programs exist only in the realm of computers, and relational databases are utilized primarily, if not exclusively, on computers."

DataTern, Inc. v. MicroStrategy, Inc., 1-11-cv-12220 (MAD September 4, 2015, Order) (Saylor, J.)