Patent Subject Matter Eligibility

District Courts, Patent Subject Matter Eligibility, Utility Patent

TQ Delta v. DISH Network — Court Upholds Phase-Scrambling Patent Under Section 101 but Invalidates Its Sibling Patent as Abstract

After a patent case pending since 2015, a Delaware federal judge held that claims directing bit and phase scrambling to reduce peak-to-average power ratio are patent-eligible, but that claims for calculating scrambled phases without applying them are abstract and lack an inventive concept.

District Courts, Patent Subject Matter Eligibility, Utility Patent

BitHarmony v. Warner Bros. Discovery — Video-Transcoding Patents Survive Section 101 at Pleading Stage, but Pre-Suit Knowledge and Direct Infringement Allegations Dismissed

Sitting by designation in Delaware, Federal Circuit Judge Bryson denied dismissal on patent eligibility grounds because the complaint plausibly alleged inventive concepts, but dismissed speculative pre-suit knowledge and multi-defendant direct infringement allegations with leave to amend.

Federal Circuit, Patent Subject Matter Eligibility

Dental Monitoring SAS v. Align Technology — Federal Circuit Holds AI-Powered Dental Imaging Patents Ineligible Under § 101

The Federal Circuit affirms invalidation of two Dental Monitoring patents covering deep-learning dental arch image analysis, holding that applying generic machine learning to a new domain — orthodontic imaging — does not supply the “inventive concept” required for patent eligibility under § 101.

Federal Circuit, Patent Subject Matter Eligibility

Etison LLC (ClickFunnels) v. HighLevel — Federal Circuit Affirms Invalidity of Sales Funnel Website Patents Under Alice

The Federal Circuit affirmed that ClickFunnels’ sales-funnel website creation patents are invalid under § 101, holding that the abstract idea of “filtering information based on user preferences” cannot be rescued by conventional template-selection and sequential-webpage features, while also clarifying the burden-shifting framework for representative-claim analysis.

District Courts, Patent Subject Matter Eligibility

IngenioShare v. Epic Games — Patent for Multi-Platform Messaging Identity Struck Down Under § 101

A North Carolina federal judge dismissed a patent infringement suit against Epic Games (Fortnite) with prejudice, holding that U.S. Patent 10,142,810 — claiming a method for managing communications across services using a single user identifier — was directed to an abstract idea and lacked any inventive concept under Alice.

Federal Circuit, Patent Subject Matter Eligibility

AGI SureTrack v. Farmers Edge — Federal Circuit Affirms Farming Data Patents Are Ineligible Under §101 but Reopens Attorney’s Fees Question

The Federal Circuit affirmed that patents claiming automated farming data collection using generic computer components are directed to patent-ineligible abstract ideas under Alice, but vacated the district court’s unexplained denial of attorney’s fees and remanded for further proceedings.

District Courts, Patent Subject Matter Eligibility

Orion Labs Tech v. TalkDesk — Court Invalidates Six AI Bot Patents Under Alice but Spares Real-Time Translation Patent

A Northern District of California court dismissed six AI bot patents as ineligible under Alice but spared a seventh — a real-time translation patent — finding its claims specified how a remote server achieves multilingual group communication, rather than merely claiming the abstract idea of translation.

Federal Circuit, Patent Subject Matter Eligibility

Constellation Designs v. LG Electronics — Federal Circuit Vacates § 101 Eligibility for Functional “Optimization” Claims, Affirms Eligibility for Specific Non-Uniform Constellation Claims

In a precedential opinion, the Federal Circuit drew a sharp § 101 line between functional ‘optimization’ claims that recite a result without specifying a concrete configuration and ‘constellation’ claims that recite specific non-uniform point arrangements. It vacated summary judgment of eligibility for the former and affirmed eligibility for the latter, while affirming the underlying jury verdict, willful-infringement finding, and damages award against LG.

District Courts, Patent Subject Matter Eligibility

B.E. Technology v. Google — Delaware Court Invalidates Last Targeted Advertising Patent Claim Under §101

A Delaware federal judge granted Google summary judgment on the last remaining claim of B.E. Technology’s targeted advertising patent, finding Claim 25 of U.S. Patent No. 8,769,440 directed to the abstract idea of providing real-time targeted advertising and lacking any inventive concept under the Alice/Mayo framework.

Federal Circuit, Patent Subject Matter Eligibility

Chewy v. IBM — Federal Circuit Invalidates Web Advertising Patents Under § 101, Partially Reverses on Infringement

The Federal Circuit affirmed that IBM’s patent claims directed to identifying advertisements based on search queries are abstract ideas ineligible under § 101—using a conventional database to match ads with search results adds no inventive concept—while partially reversing on noninfringement, remanding one claim for further proceedings.

Federal Circuit, Patent Subject Matter Eligibility

Sanderling Management v. Snap — Federal Circuit Invalidates Promotional Content Distribution Patents Under § 101

The Federal Circuit affirmed that patents claiming a method for distributing digital promotional content—loading branding images when a user’s GPS location matches a specified geographic area—are directed to the abstract idea of providing information based on meeting a condition, and contain no inventive concept that transforms the claims into patent-eligible subject matter.

Federal Circuit, Patent Subject Matter Eligibility

ChromaDex v. Elysium Health — Federal Circuit Holds Isolated Vitamin B3 Supplement Patent Invalid Under § 101

The Federal Circuit affirmed that patent claims directed to isolated nicotinamide riboside (NR)—a form of vitamin B3 found naturally in cow’s milk—are directed to a natural phenomenon and ineligible under § 101, because the claims effectively read on milk with only the isolation step as a difference, and that step adds no inventive concept.

Federal Circuit, Patent Subject Matter Eligibility

Cooperative Entertainment v. Kollective Technology — Federal Circuit on CDN Patent Eligibility

The Federal Circuit reversed dismissal of Cooperative Entertainment’s patent on a peer-to-peer content delivery network architecture, holding that claims directed to a specific topology of network nodes for distributing large video files can be patent-eligible when the specific network arrangement improves how content is distributed — not merely an abstract idea of sharing data.

Federal Circuit, Patent Subject Matter Eligibility

Universal Secure Registry LLC v. Apple Inc. — Federal Circuit Holds Multi-Factor Authentication Coordination Patents Are Abstract Ideas Ineligible Under § 101

The Federal Circuit held that four patents covering methods for coordinating multi-factor authentication across secure registries, PINs, biometrics, and universal devices are directed to abstract ideas and lack an inventive concept sufficient to confer patent eligibility.

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