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Patent Subject Matter Eligibility

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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.

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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.

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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.

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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 clarifyi

Federal Circuit
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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

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