BSG TECH LLC v BUYSEASONS, INC., decided August 15, 2018

U.S. Patent Nos. 6,035,294; 6,243,699; and 6,195,652 are directed to a self-evolving generic index for organizing information in a database.  Class (e.g., used), parameter (e.g., color), and value (e.g., red) are used to organize (page 2).  To overcome specificity in prior art approaches, users may add new parameters – self-evolving – based on usage notation (pages 3-4).  The claims are directed to considering historical usage while inputting data (page 8).  There is nothing about the database structure itself to allow input (page 8).  This focus of guiding users is not necessarily rooted in computer technology to overcome a problem specifically arising in databases (page 8).  Structuring the database to allow entry is more specific than a generic computer, but also common (page 9).  The benefit of quality of added information (i.e., what is added) is not an improvement in the way data is stored or accessed (i.e., way the database functions) (pages 11-13).  For step two (substantially more), limitations other than the use of the ineligible concept must be more than routine or conventional (i.e., performing the abstract is not enough) (page 17).  Guiding users is both what was abstract and unconventional, so does not provide substantially more (pages 17-18).

Hindsight:  Reciting components more specifically than a generic computer does not preclude a claim from being abstract.  The improvement should be to the function of the computer based on how the database structure is different.  Adding a focus on how to implement may have helped.  Teaching a new way to structure the database would have helped, but there simply may not have been such a new way in this idea.