Teradata US, Inc. v. SAP SE

Background

Teradata alleged that SAP SE, SAP America, Inc., and SAP Labs, LLC infringed five patents. The motion addressed claims involving U.S. Patent No. 7,185,000 (the ’000 Patent), titled “Method And Apparatus For Presenting Query Plans,” and also challenged Teradata’s allegations of indirect infringement for all five patents.

The ’000 Patent described presenting a query’s execution plan through a graphical user interface. The claimed system involved parallel database systems, multiple processors or virtual processors, and, in some claims, emulation data representing a target database system. Teradata argued that the invention did more than display information because it determined execution plans and used virtual processors and emulated environments.

Patent Eligibility Under Section 101

SAP moved under Federal Rule of Civil Procedure 12(b)(6), which allows dismissal when a complaint does not state a legally sufficient claim. SAP argued under the two-step framework from Alice Corp. Pty. Ltd. v. CLS Bank International that the ’000 Patent was directed to the abstract idea of displaying selected information about database queries and lacked an additional inventive concept.

At the first Alice step, the court found that the patent’s inventive concept was abstract. The court concluded that the claims and patent materials focused on using a graphical interface to display and depict query-execution plans. The requirements involving virtual processors and parallel databases supplied the information for the display but did not change the character of the claimed invention.

At the second Alice step, the court considered whether the claim elements, individually or in combination, added enough to transform the abstract idea into a patent-eligible invention. The court agreed with SAP that the patent did not adequately describe how the virtual processors, controllers, or graphical interface performed the asserted innovation. The court characterized the claimed display functionality as a generic “black box.” It also held that the Patent Office’s earlier conclusion that claim 1 was not obvious over prior art did not decide or control the separate patent-eligibility question under Section 101.

The court therefore granted SAP’s motion to dismiss the claims of the ’000 Patent as patent-ineligible.

Indirect Infringement Allegations

SAP separately argued that Teradata had not adequately alleged the knowledge and specific intent required for indirect infringement of the five asserted patents. SAP challenged the allegations concerning pre-suit knowledge for some patents and argued that the allegations of intent to induce infringement were insufficient.

The court found Teradata’s allegations sufficient at the pleading stage. It concluded that Teradata adequately alleged pre-suit knowledge for the ’357, ’000, and ’923 patents and alleged post-suit knowledge for all patents at issue. The court also found sufficient Teradata’s allegations that SAP instructed users to run and test SAP Hana in ways consistent with the claimed methods and encouraged United States customers to use SAP Hana through advertising, marketing, and product support.

Disposition

The court granted SAP’s motion to dismiss Teradata’s claims concerning the ’000 Patent as patent-ineligible. It denied SAP’s motion to dismiss Teradata’s indirect-infringement allegations. The opinion does not state that either ruling was with or without prejudice.