The Federal Circuit’s recent decision in Constellation Designs, LLC v. LG Electronics Inc., Case No. 24-1822 (Fed. Cir. Apr. 28, 2026) provides an important new roadmap for evaluating software and communications patents under 35 U.S.C. § 101. The opinion draws a sharp distinction between claims that merely recite a desired optimization result and claims directed to specific technical implementations.
The case arose from patents relating to digital communication systems, including over-the-air ATSC 3.0 television broadcasting (U.S. Patent Nos. 8,842,761; 10,693,700; 11,019,509; and 11,018,922). The patents generally involved “non-uniform constellations” used in signal transmission systems to improve data capacity and performance at lower signal-to-noise ratios. The jury found infringement and awarded more than $1.6 million in damages, along with willfulness findings against LG. But the Federal Circuit partially reversed on patent eligibility grounds.
The opinion is notable because the court upheld some claims while invalidating others within the same patent family. In doing so, the Federal Circuit offered a relatively detailed explanation of when mathematically oriented communications claims cross the line into abstract, result-oriented claiming.
The Technology at Issue
Digital communication systems convert streams of digital bits into analog signals for transmission across a communication channel. At the receiving end, those analog signals are converted back into digital information. The patents focused on “constellations,” which are graphical representations of signal points used to map digital information into transmittable analog signals.
Traditional communication systems used “uniform” constellations that maximized the minimum distance between constellation points, known as “dmin.” The inventors instead pursued “non-uniform” constellations optimized for “parallel decode capacity” (“PD capacity”), which they contended improved performance at lower signal-to-noise ratios.
The patents described iterative optimization techniques for selecting constellation point locations to maximize capacity. But as the Federal Circuit later emphasized, not all claims actually recited those implementation details.
The Court Divides the Claims Into Two Categories
The Federal Circuit grouped the asserted claims into two categories:
- “Optimization claims” that broadly recited constellations “optimized for capacity using parallel decode capacity”; and
- “Constellation claims” that recited specific non-uniform constellation structures and arrangements.
That distinction ultimately determined the outcome under § 101.
The Optimization Claims Failed Under Alice
Representative claim 17 of the ’761 patent recited a receiver using a “geometrically spaced symbol constellation optimized for capacity using parallel decode capacity.”
The Federal Circuit held those claims patent ineligible.
The panel concluded that the claims were directed to the abstract idea of “optimizing” a constellation for PD capacity, without reciting sufficient details about how the optimization was achieved. The court repeatedly characterized the claims as “result-oriented.”
Judge Stoll’s opinion relied heavily on O’Reilly v. Morse and ChargePoint v. SemaConnect. The court analogized the claims to Samuel Morse’s impermissibly broad telegraph claim because the claims effectively covered all ways of achieving the stated optimization result.
The court stressed that the claims themselves lacked meaningful implementation constraints:
“The claim itself does not recite how to achieve a constellation ‘optimized’ for PD capacity.”
The opinion repeatedly returned to the distinction between claiming a technological result and claiming a technological mechanism.
Importantly, the court acknowledged that the specification contained technical details and iterative optimization procedures. But it refused to import those limitations into the claims:
“The specification cannot be used to import details from the specification if those details are not claimed.”
That statement continues a long-running trend in Federal Circuit § 101 jurisprudence emphasizing claim language over technical disclosure.
Charles Gideon Korrell notes that the court’s reasoning closely tracks recent Federal Circuit skepticism toward claims that describe desired functional outcomes while omitting operational constraints. The opinion effectively warns patentees that detailed specifications alone are not enough if the claims themselves remain highly generalized.
The Court Also Rejected Alice Step Two Arguments
Constellation argued that its invention improved digital communication efficiency and achieved significant technical benefits over prior approaches. The company also pointed to evidence that industry participants credited the inventors with advancing non-uniform constellation optimization techniques.
The Federal Circuit was unpersuaded.
The panel held that the alleged inventive concept was merely the abstract idea itself. According to the court, a claim cannot survive Alice step two if the purported inventive concept is simply the desired optimization result recited at step one.
The court also rejected arguments that novelty or nonobviousness established eligibility, reiterating that §§ 102 and 103 are distinct from § 101.
The Constellation Claims Survived
The outcome was very different for the second category of claims.
Representative claim 21 of the ’509 patent recited specific non-uniform constellation arrangements, including overlapping constellation point locations.
Unlike the optimization claims, these claims did not merely recite the idea of “optimizing” a constellation. Instead, they claimed specific constellation structures produced by the inventors’ techniques.
The Federal Circuit emphasized that these claims covered “concrete implementations” directed to a technological improvement in communications systems.
The court found particularly important that the claims recited:
- Unequally spaced constellation points;
- Different labels for the constellation points; and
- Overlapping constellation point locations.
Those structural constraints gave the claims sufficient specificity to survive Alice step one.
The panel therefore affirmed eligibility for the constellation claims without even reaching Alice step two.
Charles Gideon Korrell believes this portion of the opinion may prove especially important for communications, AI, and signal-processing patents. The decision suggests that mathematically intensive claims can still survive § 101 if they claim sufficiently concrete implementations rather than generalized optimization goals.
The Court Also Clarified Standard-Based Infringement Proofs
The Federal Circuit also addressed an increasingly important issue in standard-essential and standards-related litigation: whether patentees may combine standard-compliance evidence with product-specific evidence to prove infringement.
LG argued that under Fujitsu v. Netgear, a patentee may rely on an industry standard only if the standard itself satisfies every claim limitation.
The Federal Circuit rejected that position.
Instead, the court held that patentees may rely on standards evidence for some claim limitations while using direct product evidence for others. The court reasoned that infringement remains a limitation-by-limitation inquiry, and judicial efficiency supports allowing standard-based proofs where appropriate.
That aspect of the opinion may significantly benefit patentees asserting communications and semiconductor patents tied to technical standards.
Damages Ruling Remains Intact
The Federal Circuit also affirmed the damages award and rejected LG’s Daubert challenge to Constellation’s damages expert.
LG argued that the expert improperly relied on allegedly incomparable Zenith license agreements as built-in apportionment evidence. The court disagreed, concluding that sufficient evidence supported comparability between the Zenith licenses and the hypothetical negotiation at issue.
Notably, the panel also declined to disturb the damages award despite invalidating several asserted claims. The court observed that the damages testimony tied value to the underlying technology rather than any particular patent claim.
Practical Implications
This decision provides several important drafting and litigation lessons.
First, patentees should pay careful attention to whether claims merely describe a desired optimization result or instead recite concrete implementation details. The Federal Circuit appears increasingly hostile toward broad “optimized for” language untethered to specific operational steps or structures.
Second, claims involving mathematical techniques remain viable under § 101 if they are sufficiently tied to concrete technological implementations. The survival of the constellation claims demonstrates that not all mathematically oriented inventions are vulnerable under Alice.
Third, the opinion reinforces the continuing importance of claim drafting discipline. The specifications here contained substantial technical detail, including iterative optimization procedures and engineering explanations. But the court focused almost entirely on what the claims actually recited.
Charles Gideon Korrell notes that the opinion may encourage applicants to include narrower implementation claims alongside broader functional claims during prosecution, particularly in communications, machine learning, and signal-processing technologies.
Finally, the infringement portion of the opinion provides additional support for hybrid infringement proofs combining industry standards evidence with product-specific evidence. That holding may become increasingly important in modern technology cases involving standardized protocols and interoperability requirements.