Patent Subject Matter Eligibility

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.

Federal Circuit, Patent Subject Matter Eligibility

Yu v. Apple — Federal Circuit Holds Dual-Camera Patent Claims Directed to Abstract Idea

The Federal Circuit affirmed that Yu’s patent on a digital camera using two lenses and two image sensors to produce an enhanced digital image was patent-ineligible under § 101 — holding the claims were directed to the abstract idea of ‘taking two pictures and using one to enhance the other’ even though the claims recited physical camera components.

Federal Circuit, Patent Subject Matter Eligibility

In re Board of Trustees of the Leland Stanford Junior University — Federal Circuit Holds Haplotype Phasing Mathematical Algorithm Is Patent Ineligible Under § 101

The Federal Circuit affirmed that Stanford’s patent claims directed to a computational method for haplotype phasing — determining which genetic variants are inherited together on each chromosome — were patent ineligible as abstract mathematical calculations implemented on generic computer hardware.

Federal Circuit, Patent Subject Matter Eligibility

American Axle & Manufacturing v. Neapco Holdings — Federal Circuit Finds Driveshaft Tuning Method Directed to Natural Law

A divided Federal Circuit panel held that American Axle’s patent on a method for tuning a propshaft to reduce vibration was patent-ineligible as directed to the application of Hooke’s Law — drawing sharp dissents and a petition for rehearing that generated significant debate about the scope of § 101’s natural law exception for mechanical patents.

Federal Circuit, Patent Subject Matter Eligibility

Packet Intelligence LLC v. NetScout Systems, Inc. — Federal Circuit Holds Deep Packet Inspection Patents Eligible, Reverses Pre-Suit Damages for Marking Failure

The Federal Circuit upheld the patent eligibility of network traffic monitoring patents under § 101, finding they recite a concrete technical solution to the problem of tracking multi-flow network conversations, but reversed pre-suit damages because the patent owner failed to comply with the patent marking requirement.

Federal Circuit, Patent Subject Matter Eligibility

American Axle v. Neapco Holdings — Federal Circuit Holds Driveshaft Manufacturing Method Claims Ineligible Under Hooke’s Law

The Federal Circuit held that patent claims directed to manufacturing driveshaft liners that “attenuate” vibrations were invalid under § 101 because they were simply an instruction to apply Hooke’s law — a natural law — without specifying how to do so, triggering a sharp dissent warning of § 101 overreach.

Federal Circuit, Patent Subject Matter Eligibility

Cellspin Soft v. Fitbit — Federal Circuit Applies Berkheimer to Deny Motion to Dismiss on § 101 Grounds

The Federal Circuit reversed a district court’s dismissal of patent claims as ineligible under § 101, applying Berkheimer to hold that well-pleaded factual allegations about how the claimed invention was an unconventional advance must be accepted as true at the 12(b)(6) stage — limiting early § 101 dispositive motions where patents allege specific technical improvements.

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