News & Analysis as of

Patents Section 101 Appeals

Haug Partners LLP

The Application of Generic Machine Learning to New Data Environments Requires “Something More” to be Patent Eligible

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On April 18, 2025, the Federal Circuit issued an opinion in Recentive Analytics, Inc. v. Fox Corp. addressing for the first time whether patents that claim no more than the application of generic machine learning to a new...more

A&O Shearman

The CAFC Found Machine Learning Patents Ineligible Subject Matter Under § 101

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On April 18, 2025, the U.S. Court of Appeals for the Federal Circuit (“CAFC”) affirmed a decision by the U.S. District Court for the District of Delaware (“district court”) that found four Recentive Analytics, Inc....more

Eversheds Sutherland (US) LLP

First impressions: Federal Circuit finds applied AI claims ineligible for patenting under 35 USC 101

Answering a much-anticipated question of first impression, the Federal Circuit affirmed an Eastern District of Pennsylvania decision that invalidated machine learning-related patent claims as ineligible subject matter under...more

Dinsmore & Shohl LLP

Patent Claims Running on AI? Federal Circuit Says Not So Fast on Patent Eligibility

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The question of whether machine learning (ML)-based claims meet the subject matter eligibility requirements under current U.S. patent law remains hotly contested. The U.S. Court of Appeals for the Federal Circuit (CAFC)...more

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

Federal Circuit’s First Alice-Analysis for Machine Learning Patents

On Friday, April 18, 2025, the Federal Circuit addressed a question of first impression regarding the validity of certain machine-learning patents under Section 101 in Recentive Analytics, Inc. v. Fox Corp., et al.,...more

Hudnell Law Group

Federal Circuit Issues First Word on AI Patent Eligibility

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On April 18, 2025, the United States Court of Appeals for the Federal Circuit affirmed the dismissal of a patent infringement suit brought by Recentive Analytics, Inc. against Fox Corporation. See Recentive Analytics, Inc. v....more

Lowenstein Sandler LLP

Federal Circuit Tightens Standards for AI-related Patent Eligibility

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Summary: In Recentive Analytics, Inc. v. Fox Corp., No. 2023-2437 (Fed. Cir. Apr. 18, 2025), the Federal Circuit delivered a clear warning: simply applying generic AI-based models to new environments is not enough to secure...more

Fitch, Even, Tabin & Flannery LLP

IP Alerts: Federal Circuit Addresses Subject Matter Eligibility of Claims Involving Generic Machine Learning

On April 18, in Recentive Analytics, Inc., v. Fox Corp., which presented a question of first impression, the Federal Circuit held that claims that do no more than apply established methods of machine learning to a new data...more

Holland & Knight LLP

Federal Circuit: Machine Learning Patents Fail Section 101 Patent Eligibility Challenge

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The Federal Circuit's recent decision in Recentive Analytics, Inc. v. Fox Corp. (April 18, 2025) has garnered a lot of attention. This is not surprising: It hits on hot topics such as machine learning, artificial intelligence...more

Arnall Golden Gregory LLP

Federal Circuit Delivers Blow to AI-Based Patents in Precedential Decision

On April 18, 2025, the U.S. Court of Appeals for the Federal Circuit issued a precedential opinion in Recentive Analytics, Inc. v. Fox Corp. The Federal Circuit held that the Asserted Patents — which relate to methods of...more

McDermott Will & Emery

Broadcast Alert! Applying Conventional Machine Learning to New Data Isn’t Patent Eligible

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The US Court of Appeals for the Federal Circuit affirmed a district court’s ruling that patents applying established machine learning methods to new data are not patent eligible under 35 U.S.C. §101. Recentive Analytics, Inc....more

Baker Botts L.L.P.

Federal Circuit Refines Section 101 Eligibility as Applied to Machine Learning Patents

Baker Botts L.L.P. on

On April 18, 2025, the United States Court of Appeals for the Federal Circuit ("Federal Circuit") issued a significant decision in Recentive Analytics, Inc. v. Fox Corp., affirming dismissal, by the District Court of...more

MoFo Tech

Recentive: Federal Circuit’s Patent-Eligibility Guideposts for Machine-Learning Inventions

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In one of the first cases from the Federal Circuit addressing patent eligibility for machine-learning (ML) inventions, the court ruled that applying “generic” ML techniques to a new data environment to automate a task...more

Lathrop GPM

Federal Circuit Holds Machine Learning Patent Claims That Don’t Improve the Technology Are Patent Ineligible

Lathrop GPM on

On April 18, 2025, the U.S. Court of Appeals for the Federal Circuit (CAFC) decided a case of first impression regarding the intersection of patent claims directed to machine learning training and patentable subject matter...more

McDonnell Boehnen Hulbert & Berghoff LLP

Recentive Analytics, Inc. v. Fox Corp. (Fed. Cir. 2025)

For the last several years, patentees and patent practitioners have been waiting for the Federal Circuit to weigh in on the patent eligibility of machine learning models. There was an expectation that, like any other...more

Schwabe, Williamson & Wyatt PC

Latest Federal Court Cases: Recentive Analytics, Inc., v. Fox Corp.

Recentive Analytics, Inc., v. Fox Corp., Appeal No. 2023-2437 (Fed. Cir. Apr. 18, 2025) In our Case of the Week, the Federal Circuit addressed a question of first impression concerning whether developments in machine...more

Sheppard Mullin Richter & Hampton LLP

2024 Federal Circuit Case Summaries - Intellectual Property: Year End Report

We are excited to present the second edition of Sheppard Mullin’s “Year in Review” report, which provides a comprehensive summary of the key precedential Federal Circuit decisions related to patent law in 2024. Building on...more

Sunstein LLP

Federal Circuit Reverses International Trade Commission on Patent Eligibility for Composition-of-Matter Claims

Sunstein LLP on

On February 13, 2025, the U.S. Court of Appeals for the Federal Circuit (CAFC) issued a precedential decision reversing the International Trade Commission finding that US Synthetic’s composition of matter claim was not...more

Dorsey & Whitney LLP

Common Sense Approach Prevails in Determining Subject Matter Eligibility of Compositions of Matter

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Over the last 15 years, the discussion over the types of subject matter that are considered patent eligible under 35 U.S.C. § 101 has been mostly focused on the software and biological fields. Several years ago, the Federal...more

Knobbe Martens

Federal Circuit Review | February 2025

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In HD Silicon Solutions LLC V. Microchip Technology Inc., Appeal No. 23-1397, the Federal Circuit held that  all but one patent claim were invalid as obvious because the claimed material, as properly construed, was disclosed...more

McDermott Will & Emery

Federal Circuit Polishes § 101’s Abstract Idea Test

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The US Court of Appeals for the Federal Circuit reversed and remanded a determination by the US International Trade Commission regarding subject matter ineligibility under 35 U.S.C. § 101. The Court concluded that the...more

Fenwick & West LLP

Key Federal Circuit Patent Rulings Impacting Your Business - Recent Rulings - January 2025

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Contour IP v. GoPro: Federal Circuit Offers Insight into Alice’s Step One Analysis. In Contour IP v. GoPro, the Federal Circuit reversed a summary judgment order invalidating two of Contour IP’s patents directed to...more

A&O Shearman

Federal Circuit Affirms Non-Infringement At Summary Judgment On “Document Stream” Patents In Mirror Worlds Technologies, LLC v....

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Mirror Worlds Technologies, LLC ("Mirror Worlds") owns U.S. Patent Nos. 6,006,227; 7,865,538; and 8,255,439, which claim methods for storing, organizing, and presenting data in time-ordered streams on a computer system. In...more

A&O Shearman

District Of Massachusetts Invalidates Epigenetics Method Patents For Lack Of Eligible Subject Matter

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In biomodal Ltd. v. New England BioLabs, Inc., No. 24-cv-11697-RGS, Dkt. No. 78 (D. Mass. Nov. 2024), Defendant New England BioLabs, Inc. (“NEB”) filed a motion to dismiss the claims of infringement of five patents as...more

Sheppard Mullin Richter & Hampton LLP

Another Example of Ineligible Software Patent Claims

Miller Mendel Inc. filed a lawsuit against the City of Anna, Texas (“the City”), in the U.S. District Court for the Eastern District of Texas, alleging infringement of Claims 1, 5, and 15 of U.S. Patent No. 10,043,188 (the...more

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