Summary
This article covers the Madras High Court patent judgment in Ab Initio’s favor, setting aside the refusal of its data lineage software patent and reinforcing the need to assess technical contributions in computer-implemented inventions.
This post discusses the Madras High Court’s judgment dated 4 November 2025 in Ab Initio Technology LLC (hereinafter as “ab initio”) Vs. The Controller of Patents & Designs (hereinafter as “Controller”), where the Court set aside the refusal of a patent application dealing with graphic representations of data relationship. The Court noted that the Controller erred in concluding that the invention lacked of novelty and inventive step, and upon analysing the cited prior art, found that the invention met the requirements under Section 2(1)(j). The judgement reinforces an important principle that the computer-implemented inventions which demonstrate a clear technical contribution, solve a specific technical problem, and are distinguishable from prior art on substantive technical features must be assessed on their merits, rather than rejected merely due to their software-driven nature.
Background
Ab initio filed a national phase patent application (4693/CHENP/2010) relating to generating graphical representations of data relationships. After examination, the Patent office raised objections under Sections 2(1)(j), 3(k), 3(n), and 10(4)(c). Hearings were conducted and finally the Controller refused the application on 13 July 2020, primarily on grounds of lack of novelty and inventive step under Section 2(1)(j), and nonpatentability under Section 3(k) of the Patents Act, 1970. Ab initio appealed this refusal before the Madras High Court.
Issues Before the Court
- Whether the claimed invention lacked novelty under Section 2(1)(j).
- Whether the invention was obvious to a person skilled in the art (PSITA) in view of D1.
- Whether the claimed subject matter fell within the exclusion of Section 3(k) as a computer programme per se.
Ab-initio’s independent claim 1:
A method for presenting a data lineage diagram indicating relationships among metadata items (302) stored in a metadata management system (340) accessible to a computing system, the method including:
receiving a request (314) that identifies a first metadata item stored in the metadata management system (340) from a user interface (300);
retrieving at least a first configuration information set from storage (360) that stores multiple configuration information sets, where each configuration information set includes a plurality of selection specifications for executing queries from the computing system to select metadata items in the metadata management system (340) that are related to a given metadata item of a predetermined type, where each configuration information set in the storage (360) includes different selection specifications, and where each selection specification from the first configuration information set is associated with a different respective predetermined type;
querying the metadata management system (340) using one or more selection specifications from the first configuration information set to identify a set of one or more metadata items that are related to the first metadata item;
where a first selection specification from the first configuration information set is associated with a type of the first metadata item; and
generating a data lineage diagram indicating data lineage relationships among programs and data represented by the metadata items identified using the first configuration information set, the data lineage diagram including nodes that correspond to the programs and data represented by the metadata items and edges that represent the data lineage relationships among the programs and data represented by the metadata items.
Ab initio’s Submissions
Ab initio argued that D1 did not disclose or suggest the claimed method of retrieving, tracing, and visually representing complete upstream and downstream data lineage, nor the method of identifying specific data items (such as problematic or modified data) within a chain. Ab initio emphasized that D1 dealt with data hierarchies of entities and relationships, whereas the claimed invention was directed to data lineage across entire data sets, involving configuration information, metadata querying, and dynamic lineage retrieval.
Placing reliance on several judicial precedents on anticipation, inventive step, and computer-related inventions, Ab Initio contended that its claims were neither anticipated nor obvious, the invention produced a clear technical contribution and that the Controller’s findings on novelty, inventive step, and Section 3(k) were unsustainable.
Controller’s Position
The Controller maintained that the invention merely involved representation of relationships and querying metadata, which was already disclosed in D1. D1, according to the Controller, provided sufficient teachings, rendering the claimed invention obvious. The Controller also contended that the claims were directed to a computer programme per se under Section 3(k) and that certain claim amendments exceeded the permissible scope.
Analysis and Findings
The Court began the analysis by carefully examining the specification to identify the core contribution of the invention. The Court observed that the invention specifically addressed the problem of tracking upstream and downstream lineage of data items in a data set, allowing retrieval of the first data item, last data item, and intermediate items, along with identification of modified or problematic data.
Novelty
Placing reliance on The General Tire & Rubber Co. v. The Firestone Tyre & Rubber Co. Ltd., [1972] RPC 457, the Court noted that D1 did not contain clear and unmistakable directions to perform the claimed invention. While D1 dealt with entity hierarchies, the Court highlighted that it was not designed or programmed to retrieve complete lineage across a data set, nor to identify intermediate or altered data items. Hence, novelty was established.
Inventive Step
The Court observed that although D1 disclosed data hierarchies and originating data sources, it did not teach tracing every upstream or downstream data item or addressing problems such as identifying corrupted or modified data within a data lineage. The Court opined that D1 was analogous prior art but did not provide sufficient teachings to lead a Person Skilled in the Art (PSITA) to the claimed invention.
Placing reliance on Agriboard International LLC v. Deputy Controller of Patents, 2022:DHC:1206 and Agfa NV v. Assistant Controller of Patents & Designs, 2023:DHC:4030, the Court reiterated that the inventive step analysis must consider the specific problem addressed and the differences between the invention and the prior art. The Court concluded that even with D1 and common general knowledge, PSITA would not arrive at the claimed invention “absent ingenuity.” Thus, the Court concluded that the invention satisfied the requirements of inventive step under Section 2(1)(j).
Section 3(k)
Although arguments under Section 3(k) were raised, the Court did not find it necessary to enter deep into this issue after concluding that the invention involved a technical contribution, consistent with principles in Lava International Ltd. v. Telefonaktiebolaget LM Ericsson, 2024:DHC:2698 and Raytheon Co. v. Controller General of Patents, 2023:DHC:6738.
Conclusion
Observing that the Controller’s findings could not be sustained, the Court allowed the appeal, set aside the refusal order dated 13 July 2020, and directed that ab initio’s patent application proceed to grant on the basis of the last submitted claims. No order as to costs was made.
Citation: (T)CMA(PT) No.58 of 2023 OA/57/2020/PT/CHN
https://indiankanoon.org/doc/28337233/
Article review and accessibility review: Dr. Neetha Mohan
