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Accenture Global Services v. Guidewire Software

Citations: 800 F. Supp. 2d 613; 2011 U.S. Dist. LEXIS 57853; 2011 WL 2148636Docket: Civ. No. 07-826-SLR

Court: District Court, D. Delaware; May 31, 2011; Federal District Court

Narrative Opinion Summary

This case involves Accenture Global Services, GmbH, and Accenture, LLP, who filed a lawsuit against Guidewire Software, Inc., alleging patent infringement of their software patents, particularly United States Patent Nos. 7,013,284 and 7,017,111, which relate to software for insurance transaction tasks. The dispute includes additional claims of trade secret misappropriation and unfair competition. The court dismissed non-patent claims but allowed Accenture to amend to reassert trade secret claims. Guidewire countered with defenses questioning the patents' validity and filed motions for summary judgment on grounds of patent invalidity, arguing the claims were abstract ideas under 35 U.S.C. § 101. The court agreed, granting Guidewire's motion for summary judgment, finding the patents unpatentable as they merely involved organizing data without specific technical applications. Accenture's motions, including a motion to strike parts of Guidewire's reply, were denied as moot. The court also addressed procedural motions, denying Guidewire's request for reargument and interlocutory appeal under Local Rule 7.1.5 and 28 U.S.C. § 1292(b), as they lacked new evidence or substantial grounds for differing opinions. Jurisdiction was established under 28 U.S.C. 1338, and the case remains unresolved with a trial not yet scheduled.

Legal Issues Addressed

Interlocutory Appeal Eligibility under 28 U.S.C. § 1292(b)

Application: The court assessed Guidewire's request for interlocutory appeal, determining it did not meet the criteria for a substantial ground for a difference of opinion.

Reasoning: A disagreement with a district court's ruling does not meet the criteria for "a substantial ground for a difference of opinion" under 28 U.S.C. § 1292(b).

Patent Invalidity under 35 U.S.C. § 101

Application: The court evaluated whether the claims in the '284 and '111 patents were abstract ideas lacking concrete application, ultimately finding them unpatentable under 35 U.S.C. § 101.

Reasoning: The court concludes that the '284 and '111 patents pertain to abstract methods and systems for managing tasks related to insurance claims, as they involve organizing data rather than defining specific devices or systems.

Reargument under Local Rule 7.1.5 and Fed. R. Civ. P. 59(e)

Application: Guidewire's motion for reargument was denied as it failed to present new evidence or show the need to correct a legal error.

Reasoning: Guidewire's motion merely reiterates previously addressed arguments without introducing new evidence or legal standards. Thus, the court denies the reargument request.

Summary Judgment Standards under Fed. R. Civ. P. 56(c)

Application: The court considered motions for summary judgment by assessing whether there were genuine issues of material fact, viewing evidence in the light most favorable to the nonmoving party.

Reasoning: A court may grant summary judgment when the evidence, including pleadings and affidavits, indicates no genuine issue of material fact exists, and the moving party is entitled to judgment as a matter of law, as per Fed. R. Civ. P. 56(c).