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Patent Subject Matter Eligibility

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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

U.S. District Court, Southern District of California
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Rich Media Club v. MediaNews Group — Court Dismisses All Ad-Tech Patent Claims as Patent-Ineligible Under Section 101

A federal court in the Southern District of California dismissed all claims from five ad-viewability and ad-refresh patents as patent-ineligible under Section 101, finding they recite abstract ideas of determining whether a webpage area is visible and sending content based on that determination.

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Rich Media Club v. MediaNews Group — Court Dismisses All Ad-Tech Patent Claims as Patent-Ineligible Under Section 101

A federal court in the Southern District of California dismissed all claims from five ad-viewability and ad-refresh patents as patent-ineligible under Section 101, finding they recite abstract ideas of determining whether a webpage area is visible and sending content based on that determination.

U.S. District Court, Northern District of California (San Jose Division)
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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 translat

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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 translat

Federal Circuit
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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

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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

Federal Circuit
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In re Hybir, Inc. — Federal Circuit Dismisses §101 Patent Eligibility Appeal as Moot Over $100 Settlement Side-Bet

The Federal Circuit dismissed a §101 patent eligibility appeal as moot after discovering the parties’ settlement agreement gave the defendant a $100 option to license the challenged patent — an amount so untethered from the patent’s value that it created no real case or controversy.

U.S. District Court for the District of Delaware
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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

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