Magistrate Judge Christopher J. Burke recently recommended the denial of § 101 motions relating to cloud computing environment technology. Kaavo Inc. v. Amazon.com Inc., et al., C.A. No. 15-638-LPS-CJB (D. Del. Nov. 3, 2016); Kaavo Inc. V. Tier 3, Inc., et al., C.A. No. 15-640-LPS-CJB (D. Del. Nov. 3, 2016). For purposes of its analysis, the Court focused on the defendants’ argument that the patent-in-suit was directed to “an abstract idea . . . of setting up and managing a computing environment.” Id. at 9. The Court ultimately agreed that the patent was directed to an abstract idea, but recommended denial of the § 101 motion under the second “inventive concept” prong of Alice, namely because, on the record before the Court, certain claim language “renders it more plausible that claim 11 describes a sufficiently specific way of ‘setting up a cloud computing environment’,” id. at 22 (emphasis added), and “there appear to be disputed issues of fact here that, when resolved, will bear on whether claim 11’s method would risk disproportionately tying up the use of the underlying ideas[,] . . . or cover all possible ways to achieve the provided result[.]” Id. at 23 (quotation marks omitted).