News & Analysis as of

Alice/Mayo Appeals

McDermott Will & Schulte

Can’t patent idea of using asynchronous data streams during web conferencing

The US Court of Appeals for the Federal Circuit affirmed a district court’s dismissal of a patent infringement suit, holding that the asserted web conferencing claims were directed to an abstract idea, lacked any inventive...more

Sheppard Mullin Richter & Hampton LLP

Not A Categorical Ban: Federal Circuit Narrowed Spectrum of Patent Eligible Machine Learning Claims

Recentive Analytics, Inc. v. Fox Corp., No. 23-2437 (Fed. Cir. 2025) – On April 18, 2025, the Federal Circuit upheld the district court’s dismissal of the case on the ground that the patents were ineligible under § 101....more

Alston & Bird

Patent Case Summaries | Week Ending January 23, 2026

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Our Patent Case Summaries provide a weekly summary of the precedential patent-related opinions issued by the Court of Appeals for the Federal Circuit and the opinions designated precedential or informative by the Patent Trial...more

Holland & Knight LLP

Signal Lost: Federal Circuit Says "Combining and Decoding" Doesn't Meet Section 101 Eligibility

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The U.S. Court of Appeals for the Federal Circuit affirmed a district court judgment holding asserted claims of U.S. Patent No. 8,139,652 ineligible under 35 U.S.C. § 101 in Technology in Ariscale, LLC v. Razer USA Ltd.,...more

Fish & Richardson

PTAB Reverses § 101 Rejection Under Desjardins Framework

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The Patent Trial and Appeal Board (PTAB) has issued a decision in an ex parte appeal reversing an examiner’s final rejection under 35 U.S.C. § 101 of claims directed to artificial intelligence (AI) based business methods. Ex...more

International Lawyers Network

The Recent Expansion of Patent Eligibility for AI Inventions Before the USPTO

Introduction - The new United States Patent and Trademark Office (USPTO) Director John A. Squires was sworn in on September 22, 2025 and wasted no time that week in expanding patent eligibility for AI related inventions. In...more

McDonnell Boehnen Hulbert & Berghoff LLP

Beyond the Noise: Unpacking Four Years of Data on PTAB’s Consistent § 101 Hostility

The state of patent eligibility appeals under 35 U.S.C. § 101 before the Patent Trial and Appeal Board (PTAB) of the U.S. Patent and Trademark Office (USPTO) is defined by a singular, overwhelming finding — abysmally low...more

Morrison & Foerster LLP

USPTO Director Signals Support for AI Patent Eligibility

Just days after John A. Squires was sworn in as the 60th Director of the U.S. Patent and Trademark Office (USPTO) on September 23, 2025, he convened the rarely used Appeals Review Panel (ARP) and issued a decision in Ex parte...more

McDonnell Boehnen Hulbert & Berghoff LLP

PTAB § 101 Appeal Stats for 2024: The More Things Stay the Same, the Worse They Remain

Each year since 2021, we have examined how the U.S. Patent and Trademark Office Patent Trial and Appeal Board (PTAB) has been deciding appeals of § 101 rejections from examiners. And so far, the numbers have been remarkably...more

Knobbe Martens

Federal Circuit Review | August 2025

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In FMC Corp. v. Sharda USA, LLC, Appeal No. 24-2335, the Federal Circuit held that the district court erred by construing a claim term based on disclosures made in a provisional application and an unasserted patent in the...more

A&O Shearman

Federal Circuit Finds Claims of Selectorized Dumbbell Weight Patent Not Directed to an Abstract Idea

A&O Shearman on

On August 11, 2025, the U.S. Court of Appeals for the Federal Circuit (“CAFC”) issued an opinion reversing the decision of the U.S. District Court for the District of Utah that found certain claims of a selectorized dumbbell...more

McDermott Will & Schulte

Feel the burn: Mechanical improvement is patent eligible under § 101

The US Court of Appeals for the Federal Circuit reversed a district court’s partial dismissal of the plaintiff’s patent claims under 35 U.S.C. § 101, finding that the claims were not directed to an abstract idea under Alice...more

Knobbe Martens

Can § 101 Carry the Weight?

Knobbe Martens on

POWERBLOCK HOLDING, INC. v. IFIT, INC. - Before Taranto, Stoll, and District Judge Scarsi. Appeal from the United States District Court for the District of Utah. Under step one of the Alice test, claims should be considered...more

Miller Johnson

Fed. Cir. Ends Approach Employed To Make Challenging Patents As Abstract Ideas More Difficult 

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Optis Cellular Tech., LLC v. Apple Inc., No. 22-1925 (Fed. Cir. June 16, 2025) - Over a decade ago, the U.S. Supreme Court arguably made it easier to invalidate a patent for claiming nonpatentable abstract ideas when it...more

McDonnell Boehnen Hulbert & Berghoff LLP

The Preemption Doctrine: A Necessary Course Correction After Recentive v. Fox

The landscape of patent law for artificial intelligence (AI) and machine learning (ML) innovations has become fraught with uncertainty. The U.S. Court of Appeals for the Federal Circuit's precedential opinion in Recentive...more

Knobbe Martens

Patent Claims Applying Machine Learning Methods to New Environment Do Not Withstand § 101 Scrutiny

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RECENTIVE ANALYTICS, INC. v. FOX CORP. - Before Dyk, Prost, and Goldberg. Appeal from the United States District Court for the District of Delaware. The Federal Circuit found that claims applying established methods of...more

Bradley Arant Boult Cummings LLP

Another Bite at the Apple to Avoid $300 Million in Damages

Recently, the Federal Circuit vacated both the infringement and damages judgments against Apple in a patent case that involves standard-essential patents (SEPs) related to Long-Term Evolution (LTE) technology brought in the...more

Alston & Bird

Patent Case Summaries | Week Ending June 13, 2025

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Fraunhofer-Gesellschaft zur Förderung der angewandten Forschung e.V. v. Sirius XM Radio Inc., No. 2023-2267 (Fed. Cir. (D. Del.) June 9, 2025). Opinion by Lourie, joined by Dyk and Reyna....more

McDermott Will & Schulte

In Determining Subject Matter Eligibility, the Name of the Game Is the Claim

In a decision underscoring the distinct standards governing enablement under §§ 102 and 112, the US Court of Appeals for the Federal Circuit affirmed the Patent Trial & Appeal Board’s finding that a prior art reference was...more

Holland & Knight LLP

Federal Circuit Grounds Aircraft Taxability Patent Under Section 101

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Aviation Capital Partners v. SH Advisors, the U.S. Court of Appeals for the Federal Circuit affirmed the ineligibility of claims directed to determining the taxability status of aircraft based on flight data. The panel upheld...more

McDonnell Boehnen Hulbert & Berghoff LLP

The Narrow Pathway to Patent Eligibility in the Federal Circuit

The last 11 years have taught us much about the Federal Circuit; namely, that a majority of the judges simply do not seem to appreciate software. Given the statements that several have made in opinions, one might be able to...more

Miller Nash LLP

First Machine Learning Patent Ruling: Invalid or Just Obvious?

Miller Nash LLP on

On April 18, 2025, the Court of Appeals for the Federal Circuit (CAFC) ruled in Recentive Analytics Inc. v. Fox Corp. et al. that new uses for established machine learning do not make the claims patent-eligible....more

WilmerHale

Federal Circuit Patent Watch: Patents That Merely Claim Applying Machine Learning to a New Field of Use Are Not Patent Eligible

WilmerHale on

Stark, J. Sage Products, LLC (“Sage”) challenged a Patent Trial and Appeal Board (“Board”) decision finding two of Sage’s patents unpatentable. After the original appellee, Becton, Dickinson and Co., withdrew, the Director of...more

Womble Bond Dickinson

Developments in Patent Subject Matter Eligibility for Software-Related Inventions, in View of Guvera v. Spotify

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Innovators seeking patent protection for software inventions should be aware that all software inventions face patent-eligibility issues. Nevertheless, patent practitioners who are experienced in the art of software patent...more

Mintz - Intellectual Property Viewpoints

Recentive Analytics v. Fox: The Federal Circuit Provides Analysis on the Patent Eligibility of Machine Learning Claims

On April 18, 2025, the Federal Circuit remained consistent with previous Alice decisions by holding that four machine learning patents involved in a dispute between Recentive Analytics, Inc. and Fox Corp. were ineligible...more

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