News & Analysis as of

Alice/Mayo Section 101

WilmerHale

Federal Circuit Patent Watch: Patent Related to Web Conferencing Systems Found Patent-Ineligible

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Precedential and Key Federal Circuit Opinions - U.S. PATENT NO. 7,679,637 LLC v. GOOGLE LLC [OPINION] (2024‑1520, 01/22/2026) (Moore, Hughes, Stoll) - Moore, C.J. The Court affirmed the district court’s dismissal of U.S....more

Sterne, Kessler, Goldstein & Fox P.L.L.C.

IP Hot Topic: Federal Circuit’s RPI v. Amazon Questioning Tests the Boundaries of Machine Learning Patent Eligibility...

Less than a year after holding that generic machine-learning patents are abstract in Recentive Analytics, Inc. v. Fox Corp., the Federal Circuit may be refining where to draw the line on patent eligibility....more

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

Hudnell Law Group

Result-Oriented Software Claims Fall Short as Federal Circuit Demands Technological Improvement

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On January 22, 2026, the United States Court of Appeals for the Federal Circuit affirmed the Rule 12 dismissal of a patent infringement action brought by US Patent No. 7,679,637 LLC against Google LLC, holding that the...more

Baker Botts L.L.P.

A New Playbook for § 101? The USPTO's Guidance on Using Technical Evidence

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Section 101 eligibility remains one of the most unpredictable and frequently contested areas of U.S. patent practice, particularly for software, artificial intelligence, and machine learning....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

Fenwick & West LLP

Federal Circuit Issues Precedential Decision Reframing Patent Eligibility Analysis Under Section 101

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Patent eligibility decisions are not new. Courts have grappled with what can and cannot be patented for years, especially in the technology and software spaces. A recent decision from the U.S. Court of Appeals for the Federal...more

Fish & Richardson

Texas Round-Up: December 2025

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Our Texas Round-Up for December 2025 covers decisions from the Eastern District addressing subject matter eligibility under Section 101 and the timeliness of expert opinions on non-infringing alternatives....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

Wolf, Greenfield & Sacks, P.C.

Avoiding the “Atomic Bomb of Patent Law”

The U.S. Court of Appeals for the Federal Circuit once called the remedy for inequitable conduct “the atomic bomb of patent law.” Inequitable conduct is a defense against patent infringement that can render a patent...more

McDonald Hopkins

The recent expansion of patent eligibility for AI inventions before the USPTO

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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. ...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

Holland & Knight LLP

Patent Eligibility Reform: Everyone Has an Opinion (and a "Love Actually" Relationship Ranking)

Holland & Knight LLP on

Section 101 Blog If you work anywhere near patent eligibility, the rhythm is familiar. Another year, another reform drumbeat. Draft language circulates on the Hill. Industry groups publish letters. Academics and the familiar...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

Maynard Nexsen

Patent Trolls: Seven Steps to Stop Them and How They Are Contributing to the 20% Uptick in Patent Litigation in 2025

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Who should read this article? Companies sued by patent trolls (NPEs) seeking to develop strategies to push back against NPE activity—and specifically companies in the following industries...more

Lowenstein Sandler LLP

USPTO Outlines New Path for Overcoming § 101 Rejections Through Rule 132 Subject Matter Eligibility Declarations

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What’s New: USPTO Embraces Evidence-Driven § 101 Practice - The U.S. Patent and Trademark Office (USPTO) recently issued two coordinated memoranda explaining how applicants can use Subject Matter Eligibility Declarations...more

Foley Hoag LLP

Guidance on Rule 132 Declarations for Patent Eligibility

Foley Hoag LLP on

Key Takeaways - Easier path to eligibility: The USPTO’s new guidance explains how to use sworn statements (SMEDs) to provide facts showing an invention is eligible for a patent....more

McDonnell Boehnen Hulbert & Berghoff LLP

Why the Alice Test is Stupid, Part IV: The Usefulness Paradox

One might be forgiven for assuming, based on a cursory reading of the Constitution or perhaps a fleeting bout of logic, that the U.S. patent system exists to promote the progress of science and useful arts. Historically, this...more

BakerHostetler

Strategies and Considerations for Optimally Using Subject Matter Eligibility Declarations Before the USPTO

BakerHostetler on

On Dec. 4, 2025, U.S. Patent and Trademark Office (USPTO) Director Squires issued new guidance to patent examiners and applicants via a pair of memoranda (Guidance) encouraging the use of subject matter eligibility...more

Womble Bond Dickinson

USPTO Suggests Use of Rule 132 Declarations and Updated Examiner Guidelines to Address Patent Subject Matter Eligibility Issues

Womble Bond Dickinson on

In follow up to the August 4, 2025 guidance and September 26, 2025 In re Desjardins decision, the USPTO recently took another significant step to provide patentees pursuing patent protection additional tools to address patent...more

Seyfarth Shaw LLP

Hottest Patent Term of 2026? SMED.

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Every year has its “it” term.In 2025, the crown belonged to AI, and rightfully so. AI dominated the headlines, flooded the USPTO’s dockets, and triggered more §101 rejections than any examiner would care to admit. If you...more

ArentFox Schiff

SMEDs in the Spotlight: USPTO Memo Highlights Use of Rule 132 Declarations for § 101

ArentFox Schiff on

On December 4, the US Patent and Trademark Office (USPTO) issued a memorandum to the Patent Examining Corps reinforcing its existing subject matter eligibility framework under 35 U.S.C. § 101 and calling renewed attention to...more

McDonnell Boehnen Hulbert & Berghoff LLP

USPTO Issues Memoranda on Subject Matter Eligibility

Late last week, the U.S. Patent and Trademark Office (USPTO) published three memos addressing its latest policies regarding subject matter eligibility. These included “Subject Matter Eligibility Declarations” from Director...more

Morrison & Foerster LLP

USPTO Puts Subject Matter Eligibility Declarations in the Spotlight

On December 4, 2025, U.S. Patent and Trademark Office (USPTO) Director John Squires issued two memoranda addressing subject matter eligibility and spotlighting an additional pathway to overcome a rejection under 35 U.S.C. §...more

Venable LLP

The § 101 Reset for 2026

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Patent practitioners have seen a shifting landscape for patent eligibility under 35 U.S.C. § 101 since the Supreme Court’s 2012 and 2014 seminal decisions in Mayo and Alice. Now, the United States Patent and Trademark Office...more

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