BERKELEY*IEOR v. W.W. Grainger Inc.

BERKELEY*IEOR v. W.W. Grainger Inc. The Federal Circuit held that the asserted claims are patent ineligible because they are directed to the abstract idea of calculating profitability and do not recite an inventive concept. The alleged improvement—parallel processing inside an RDBMS—could not supply an inventive concept because the claims did not require parallel processing. The decision reinforces that an alleged computer-performance improvement cannot save claims under Alice step two unless the claims actually require the feature that provides the improvement. Reversed the district court's grant of summary judgment of patent eligibility and affirmed judgment for Teradata and the customer defendants on Counts I–V on the alternative ground of patent ineligibility; the court did not reach Berkeley's appeal issues. The representative claim covered determining object-level profitability by preparing information, establishing processing rules in a relational database, calculating marginal profit and a fully absorbed profit adjustment value, and combining them. At Alice step one, the court agreed the claim was directed to the abstract idea of calculating profitability using mathematical analysis on a computer. At Alice step two, the district court had relied on parallel processing as an inventive concept, but the Federal Circuit held that was legal error because the claim scope allowed sequential processing or no parallel processing. Berkeley's alternative framing—that the RDBMS independently calculated marginal profit values internally—did not identify a distinct inventive concept; the asserted benefit still depended on unclaimed parallel processing. Because the asserted claims were ineligible, the Federal Circuit affirmed judgment for all defendants without reaching the customer-suit stay, § 271(g), indirect-infringement, or remaining direct-infringement issues. § 101 claim construction infringement injunction / stay non-precedential § 101 claim construction infringement injunction / stay non-precedential § 101 claim construction non-precedential