In Anonymous Media Research Holdings LLC v. Samsung Electronics America, Inc., No. 2:23-cv-00439 (E.D. Tex.), Judge Rodney Gilstrap denied Samsung’s motion to certify an interlocutory appeal under 28 U.S.C. § 1292(b) of the court’s earlier ruling that U.S. Patent Nos. 10,719,848 and 10,963,911 are patent-eligible under Alice Corp. v. CLS Bank International.
The patents cover methods for improving automatic content recognition (ACR) to measure media consumption. Samsung implemented the patented technology in over 50 million smart televisions in the United States and used the resulting data to power its targeted advertising business. A jury in September 2025 returned a $78.5 million verdict after finding Samsung infringed multiple claims of both patents.
Samsung sought certification to appeal the court’s summary judgment ruling that the asserted claims are not directed to abstract ideas under Alice Step One. Samsung pointed to a directly conflicting decision from the Northern District of California, where Judge Vince Chhabria invalidated the same patents under Section 101 in a parallel suit brought by the same plaintiff against Roku. Judge Chhabria concluded the patents were directed to “unpatentable abstract ideas without a saving inventive concept.”
Judge Gilstrap declined to certify the appeal. In the earlier summary judgment ruling, Magistrate Judge Roy S. Payne (whose recommendation Judge Gilstrap adopted) found the asserted claims “are directed to specific implementations of solutions to problems in the software arts” and therefore satisfy Alice Step One. Judge Payne had also noted that “a subsequent decision that disagrees with the prior decision of a different court does not require the prior court to revisit its decision.”
The ruling means the $78.5 million verdict stands for now, and Samsung cannot take an immediate appeal on the Section 101 question. The Federal Circuit will ultimately need to resolve the conflicting patent-eligibility determinations—the E.D. Texas finding the patents valid and the N.D. California finding them invalid—when appeals from both cases are consolidated or heard.
Surfaced via Law360 IP.