Bonum Certa Men Certa

Enfish Case Has Not Salvaged Software Patents in the US, Proponents of Software Patents Admit

Much ado about [En]fish...

Fish



Summary: A roundup of news about software patents in the United States and why the media's narrative (dominated by patent lawyers) clouds a rather grim reality for software patents, even after the Enfish v Microsoft case

THE USPTO continues to grant software patents, but relying on Alice at the US Supreme Court (SCOTUS), reassessments by courts or panels typically invalidate these.



SCOTUS and Halo v Pulse



"The USPTO continues to grant software patents, but relying on Alice at the US Supreme Court (SCOTUS), reassessments by courts or panels typically invalidate these."Based on this new tweet, SCOTUS now recognises the patent trolls issue and even names it as such. This commentary on trolls ought to take into account the strong correlation between patent trolling and software patents (which trolls typically use). Here is what Patently-O wrote about SCOTUS just now: "The Supreme Court today issued an important unanimous decision in Halo v. Pulse – vacating the Federal Circuit’s rigid limits to enhanced damages in patent cases. The decision rejects the dual objective/subjective test of Seagate as “inconsistent” with the statutory language of 35 U.S.C. €§284."

The problem is, irrespective of damage limitations, patent trolls (which may be the spilling of a company's patent portfolio acting as satellites) can just attack many thousands of firms or people, taxing each in turn. So loopholes remain in tact and overall it's pretty ugly.

Court of Appeals for the Federal Circuit (CAFC)



It is worth noting that there's an ever-growing gap between the judgment of USPTO examination -- as per the management's guidelines -- and what US courts actually say, even corrupt courts like the Court of Appeals for the Federal Circuit (CAFC). Remember that it was CAFC which started software patenting in the first place and recently ruled in favour of Enfish, getting software patents proponents/maximalists (such as patent lawyers) all giddy and jubilant as though software patents are back with vengeance (they're not).

Free Software



"It is worth noting that there's an ever-growing gap between the judgment of USPTO examination -- as per the management's guidelines -- and what US courts actually say, even corrupt courts like the Court of Appeals for the Federal Circuit (CAFC)."Software patents are problematic to software developers, no matter if they develop Free software or proprietary software. It's probably a bit more of a problem for Free software developers because in order to freely distribute copies of their software they must not be coerced into making patent payments to anyone. "Patents and the open-source community" is a new article from LWN which deals with the topic. It is a very long article about a panel in which Professor "Moglen advised separating the past from the future when discussing tactics. For the future, he said, "we should prevent people from getting patents." But, in the past, the problem is old patents "rising up and smiting" projects, harming innovation. The work that Choudhary does trying to abolish patents, he said, covered how to protect people in the future—and he fully expects SFLC to continue that work, arguing in front of the Supreme Court about the "design patent" case between Apple and Samsung. Furthermore, he said, "open-source software is an immense repository of prior art. Free software can help by educating people on all that we've invented and that you therefore cannot reinvent and patent.""

Samsung and Apple



Speaking of this (above-mentioned) "design patent" case between Apple and Samsung -- a case which we last wrote about in the weekend -- Florian Müller who dislikes Moglen (he once again told off the SFLC a few days ago) has "all the documents and the key points". To quote his blog: "There never was any doubt that the question of whether the infringement of a single design patent by a complex, multifunctional product warrants an unapportioned disgorgement of profits would be an extraordinarily important one. Previous rounds of amicus curiae briefs already demonstrated broadbased support. But the level of support the petition has just received at this decisive stage exceeds my expectations."

Days ago we explained why this is relevant and important to Free software. Previously we also explained why design patents are often similar if not indistinguishable from software patents (UI+callback function/s).

Patent Lawyers Upset



“There never was any doubt that the question of whether the infringement of a single design patent by a complex, multifunctional product warrants an unapportioned disgorgement of profits would be an extraordinarily important one.”
      --Florian Müller
Suffice to say, patent lawyers almost always support claimants (never mind justice or innovation). They want a lot of money to swap hands because it's their source of revenue, other than/aside from obscenely high hourly charges. "How the United States Patent Office Became the Place Where Patents Go To Die" is an example of a new article which bemoans quality control and it is promoted by the usual suspects. It's not exactly surprising that the bubble is now imploding. Patent quality became a joke and over-evaluation of patents ensued. Opponents of the Alice decision continue to cheer for software patents ("Uber files patent on hyperlocal internet search" in this case), but sadly for them, the boat is leaving and software patents are now weaker (in the US) than they have ever been since their introduction by CAFC. "Recall that Enfish comes from a single CAFC panel," IBM's Manny Schecter wrote the other day, "when the CAFC ruled en banc in Alice it was splintered" (as a reminder, Schecter is a proponent of software patents not only in the US).

Reality Check From Software Patents Proponents



“I am thus concerned that Enfish will not be as useful as hoped in overcoming €§101 Alice rejections.”
      --IP Watchdog
We were rather amused to find the most pro-software patents site out there publishing "Is Enfish Much Ado About Nothing?" The gist of it is that the Enfish decision hardly changed anything at all. To quote the key part: "I am thus concerned that Enfish will not be as useful as hoped in overcoming €§101 Alice rejections. The patents at stake in Enfish appear to have been written with a confident view of the prior art and of the invention. So, if a specification does not confidently emphasize the “invention,” its “benefits over” conventional prior art, and “disparage” the prior art, will examiners and judges continue Step 1 characterizations at “such a high level of abstraction”? Is Enfish merely much ado about nothing?"

Yes, it is. Patent lawyers tried to over-emphasise it in order to change public opinion and influence policy-making people. The patent salespeople, on the other hand (in the same site), hope that this one single case will save software patents, not just at the USPTO but also at the courts. They are not paying attention to any case other than the Enfish v Microsoft case. How convenient...

Software Patents Proponents in Denial



Almost a month later (after the decision) Baker Botts LLP is still cherry-picking cases in an effort -- however shallow -- to shore up software patents. Banana IP (Banana Republic?) does the same kind of lobbying. We have already covered dozens of examples like these. These helped show how the media, especially lawyers' media, continues to simply ignore every single case that's ruled against software patents and lean on the rare exceptions instead. Edward Bray (of Marks & Clerk) is now cross-posting his 'analysis' in favour of software patents -- an 'article' (lobbying/marketing) which we mentioned the other day. It just never stops, does it? Even a month later.

“Is Enfish merely much ado about nothing?”
      --IP Watchdog
The USPTO is doing the same thing, as we noted last month on a couple of occasions. Here is an explanation of how it goes: "Abstract idea - #USPTO memo on how the #CAFC Enfish patentability decision obstructed Alice http://www.uspto.gov/sites/default/files/documents/ieg-may-2016_enfish_memo.pdf … #swpat"

The patent office too is latching onto a single case when it serves to 'sell' more patents for more revenue. No separation between examination and policy?

Evidence serves to suggest that no matter what USPTO greed does, the courts continue to crush software patents, even after the Enfish decision. "Patents Directed to Electronic Delivery of Messages Found Ineligible in AZ in GoDaddy v. RPost," Patent Buddy wrote the other day, linking to http://assets.law360news.com/0805000/805041/2016-06-07%20(doc%20344)%20order%20granting%20godaddy_s%20motion%20summary%20judgment%20and%20vacating%20trial%20dmwest_14483743(1).pdf (Alice is mentioned dozens of times in this decision's PDF).

Many software patents have just died not only in the courts but also at PTAB, so how can patent lawyers argue with a straight face that a lot has changed? "Fatal Flaws of Subjective Alice/Mayo 101 Test [Are] Now Becoming Evident in Contradictory Findings Across Dist. Courts," Patent Buddy wrote, but why is that test "subjective"? Because patent attorneys and lawyers don't like it? Because it threatens their profit/income?

The matter of fact is that some courts get it right (they can see that algorithms are abstract), whereas some are still rather clueless (or bad lawyers for the defendant) if not corruptible, as was the case at CAFC before. Microsoft had a lot to gain from losing that case, as we explained last month.

"LinkedIn will soon be owned by Microsoft, which is itself a leading proponent of software patents."Here is a case of software patents being used against Facebook, which has been stockpiling patents on software. To quote Patently-O: "Indacon’s U.S. Patent No. 6,834,276 covers an improved database system that adds “custom links” so that instances of a “link term” would point to a particular file in the database. Thus, applying this in LinkedIn, you might find that references to “Dennis Crouch” point to my LinkedIn profile. Of course, the way that Facebook & LinkedIn operate does not create the pointer-link for all occurrences of the term."

LinkedIn will soon be owned by Microsoft, which is itself a leading proponent of software patents. What will this mean? Remember that the Enfish decision too involved Microsoft and people from Microsoft were pleased with the outcome. Speaking of Microsoft, the company is now hoarding software patents on quantum computing, based on this new listing. "Note that the USPTO also has a search engine for patent applications that are not yet granted," wrote the author. "I am not listing those here. You can use that search engine yourself if you also want to see “Previews of the Coming Attractions”..."

Microsoft is by far the biggest threat to Free software when it comes to patent aggression.

Patents on Genome



“Indacon’s U.S. Patent No. 6,834,276 covers an improved database system that adds “custom links” so that instances of a “link term” would point to a particular file in the database.”
      --Patently-O
The Alice/Mayo test applies to more than just software. Bristows lawyers (i.e. patent profiteers who promote software patents) show no concerns about patent scope expansions. Based on this article from MIP, they aren't going to say that patents on human genome are insane. Instead there's promotion of that. As per the summary: "Genomic technology has rapidly created a multi-billion dollar growth industry. With life sciences companies scrambling in US and European courts for a share of the lucrative market, in-house IP counsel should start preparing for the next wave of IP litigation, explain Dominic Adair and Annsley Merelle Ward" (from Bristows).

Unless the USPTO gets a grip and stops granting patents on everything in nature, the valuation of patents and the confidence in the patent office will further erode, leaving patent lawyers reliant on illusions, lying to their potential customers, and overselling the prospects of patent litigation. How long can this madness last? It's a bubble.

Recent Techrights' Posts

The Old Days
In the early days of this site (2006) it was mostly just a couple of people, plus comments
Links 28/03/2026: Microsoft's LinkedIn a National Security Risk, Microsoft's Slop "Ambitions Face Investor Scrutiny Amid Soaring Costs"
Links for the day
 
People Discuss Rumours of Mass Layoffs at IBM Becoming Public in 1-2 Weeks
IBM is killing its brand or its "goodwill"
LLM Slop Kills Sites, as Sites That Adopt Slop Are Doomed
People won't subscribe to such sites and visit them if they recognise it's just slop
Links 29/03/2026: Indonesia Cracks Down on Social Control Media Addiction, China Becomes World’s Scientific Superpower
Links for the day
Fedora at the Mercy of Microsoft Because of Back-Doored Kick-Switch Boot
We'll soon revisit the defamation attacks on Torvalds
Links 29/03/2026: Water Shortages and No Kings Rallies
Links for the day
Gemini Links 29/03/2026: Return to Gopherspace, "Zen of Marking Playing Cards"
Links for the day
The Real XBox is Dead, So Microsoft is Calling Everything "XBox" Now
It even wanted to run a campaign to convince everybody that XBox is not actually a console
Over at Tux Machines...
GNU/Linux news for the past day
IRC Proceedings: Saturday, March 28, 2026
IRC logs for Saturday, March 28, 2026
Open Web Destroyed by Centibillionaires, Says Anil Dash of Blogging Fame
Blogging was going through its 'prime years' about 20 years ago
"Linux" Slop Going Away, Microsoft et al Pay 'Linux' Foundation to Promote Slop
It's a timely reminder that the Linux Foundation exists to promote whoever pays the Linux Foundation, even pedophiles and companies that attack the GPL
Gemini Links 28/03/2026: "Finding My Base Tone", "Astrobotany", and BugoutBack/OFFLFIRSOCH
Links for the day
Links 28/03/2026: More Worldwide Bans on Social Control Media (Harms to Adolescents), Protests in US Against Dictatorship
Links for the day
SLAPP Censorship - Part 26 Out of 200: Asking for Documents and Information You Already Have, Even Letters and E-mails That You Yourself Sent!
barristers are expensive
Gemini Links 28/03/2026: Echo Delay and 0x0.st
Links for the day
Rumours of More IBM Mass Layoffs at Beginning of April
IBM is not doing well
Over at Tux Machines...
GNU/Linux news for the past day
IRC Proceedings: Friday, March 27, 2026
IRC logs for Friday, March 27, 2026
"Headcount" as Distraction From Mass Layoffs and Salary Reductions
Things aren't looking well when one considers revenue is acquired, not earned
"Linux" Slop Turning Rarer, New York Times Nowadays Contaminated With LLM Slop
Another day has passed without much slop about "linux"
Links 27/03/2026: Studying Whale Births, Apple is Cancelling Products, Cambodia Arrests Journalists Over Photographs
Links for the day
Gemini Links 27/03/2026: GTD, Gopher Catchup, Gemini Crawlers, and "Slop Everywhere"
Links for the day
Mozilla Was Ruined Like Sirius Open Source Was Ruined - From the Top Down
Mozilla will never return to its Free software roots
Nokia Could Never Recover From Microsoft
It's very important to remember what really happened
Why Techrights and Many Other Sites Stopped Doing April Fools’ Day Articles
Well before slop (made by LLMs) it was "bad optics" to have satire or humour in a site, irrespective of the day of the year
President Not-Cocaine Campinos Notified of Historic EPO Strikes (Thousands of Workers Not Coming Back to the Office)
Please do pay attention to how the media treats these strikes in Europe's second-largest institution
Slides From the Presentation Discussing EPO Strikes Until End of June or Until End of 2026 (Maybe Next Year Too)
More to come soon (later today)
IBM Cuts Are Everywhere (Global), the Aim is to Lower the Pay
Because the revenues keep falling (IBM buys other companies' revenues using borrowed money)
Perpetual Strikes to Begin at European Patent Office (EPO), Large Majority Votes for Strikes Any Day of the Week
Approved industrial actions [...] Notice how none of the media or even so-called 'IP' blogs write about it
Mozilla is Not a Privacy Company, Mozilla is Run by GAFAM Executives and Managers Who Came From American Surveillance Companies
Would you trust a VPN they claim to be "free"?
SLAPP Censorship - Part 25 Out of 200: That Time Matthew J. Garrett Got Temporarily Banned/Suspended From Twitter
That he gets banned from large social control media platform is hardly surprising given his combative communications
Ubuntu Started as Free With ShipIt, Now It Becomes Payware That Exploits Debian Volunteers (Slaves)
"Ubuntu" the distro now replaces the GNU components inherited from Debian with a bunch of Microsoft GitHub (proprietary) things that reject reciprocal licences
Last Night The Register MS Published a Fake Article. It Mentioned "AI" 27 Times.
Paid-for nonsense! [...] What's left of once-respectable news sites actively harms society
Links 27/03/2026: Google Executive (GAFAM, US, Surveillance) "Named the New BBC Head", Prominent Climate Scientist Resigns From NASA
Links for the day
Gemini Links 27/03/2026: "Being Busy" and "Posting Again"
Links for the day
GNOME Has No "Real" Executive Director, Only an IBM (Perma)'Interim' One With No Openings in Sight
GNOME is having financial problems
Microsoft Experiencing "Leadership Exodus"
Microsoft's current position is no better than Meta's (Facebook)
GNU/Linux Distros Should Reject "Age Verification" and Uphold Software Freedom for Users
It's not about protecting children
Slop Plunge
we can already "smell the blood" of the so-called 'AI industry'
IBM Media Puff Pieces While Layoffs Go On and On
Has the PR industry absorbed the press?
Media Says Microsoft Hiring Freezes, But There Are Already Microsoft Layoffs
They want the public to talk about Microsoft as if it's just not hiring when it is actually firing
Richard Stallman lynchings: Sruthi Chandran splitting Debian
Reprinted with permission from Daniel Pocock
Over at Tux Machines...
GNU/Linux news for the past day
IRC Proceedings: Thursday, March 26, 2026
IRC logs for Thursday, March 26, 2026