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Patent Subject Matter Eligibility

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

Federal Circuit
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Columbia University v. Gen Digital (Norton) — Federal Circuit Vacates $600M Patent Judgment, Finds Virus-Detection Claims Abstract Under Alice

The Federal Circuit vacated a $600 million patent infringement judgment against Norton (Gen Digital), holding that Columbia University’s computer virus-detection patent claims are directed to abstract ideas under Alice Step 1, and denied en banc rehearing.

Federal Circuit
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Chewy v. IBM — Federal Circuit Invalidates Web Advertising Patents Under § 101, Partially Reverses on Infringement

The Federal Circuit affirmed that IBM’s patent claims directed to identifying advertisements based on search queries are abstract ideas ineligible under § 101—using a conventional database to match ads with search results adds no inventive concept—while partially reversing on noninfringement,

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Chewy v. IBM — Federal Circuit Invalidates Web Advertising Patents Under § 101, Partially Reverses on Infringement

The Federal Circuit affirmed that IBM’s patent claims directed to identifying advertisements based on search queries are abstract ideas ineligible under § 101—using a conventional database to match ads with search results adds no inventive concept—while partially reversing on noninfringement,

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