Automatic Version Control Patent Not Invalid Under 35 U.S.C. § 101

The court denied defendant's motion for summary judgment that plaintiff's patent for providing an automatic version control to a business intelligence system was invalid for lack of patentable subject matter because the claims contained an inventive concept. "Defendants contend that taking actions 'automatically' is purely conventional and does not save the [patent-in-suit], citing numerous cases of courts invalidating claims that merely 'automated' otherwise abstract ideas or conventional computer functions. The claims at issue, however, do not merely automate a purely conventional technique or abstract idea, but rather provide an 'automated agent.'. . . It is the provision of this automated agent to solve the problem of a business intelligence system lacking native version control that amounts to significantly more than a patent on the idea of maintaining versions of electronic documents itself. . . . The claims describe an invention that serves as an addition to a business intelligence system rather than claiming a monopoly on all version control systems, particularly version control native to a business intelligence system. . . . Moreover, the [patent] does not claim version control generally, but rather a specific method, using an 'automated agent' distinct from a business intelligence system to improve the functionality of a business intelligence system."

Motio, Inc. v. BSP Software LLC et al, 4-12-cv-00647 (TXED January 4, 2016, Order) (Mazzant, J.)