Tag: eligibility
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Ollnova v. ecobee: Federal Circuit Clarifies Alice Step Two and Technical-Improvement Analysis
The Federal Circuit’s decision in Ollnova Technologies Ltd. v. ecobee Technologies ULC , Case No. 25-1045 (Fed. Cir. Jun. 4, 2026 ), delivers several significant holdings for patent litigators and technology companies. The opinion addresses jury unanimity in multi-patent trials, the proper role of juries in patent eligibility disputes under Section 101, and the distinction…
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AGI SureTrack v. Farmers Edge: Federal Circuit Rejects Data-Collection Claims Under Section 101
The Federal Circuit’s decision in AGI SureTrack LLC v. Farmers Edge Inc. , Case No. (Fed. Cir. Jun. 2, 2026), provides another significant reminder that patents directed to collecting, analyzing, and transmitting information remain vulnerable under 35 U.S.C. § 101, even when framed as solving industry-specific technical problems. At the same time, the court’s treatment…
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Constellation Designs v. LG: Federal Circuit Splits on Patent Eligibility for Signal Constellation Claims
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…
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Columbia University v. Gen Digital: $185M Cybersecurity Patent Verdict Reopened and Trial Counsel Sanctions Vacated
A pair of related decisions issued by the Federal Circuit in Trustees of Columbia University v. Gen Digital Inc. , Nos. 24-1243, -1244 (Fed. Cir. Mar 11, 2026), address two issues that often arise together in complex patent litigation: the evolving scope of patent eligibility under Alice, and the limits of sanctions imposed on litigation…
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REGENXBIO v. Sarepta Therapeutics: Recombinant AAV Host Cells Are Not Products of Nature
On February 20, 2026, the Federal Circuit issued a significant decision clarifying the scope of patent eligibility for genetically engineered compositions in REGENXBIO Inc. v. Sarepta Therapeutics, Inc., No. 2024-1408 (Fed. Cir. Feb. 20, 2026). Reversing the District of Delaware, the court held that claims directed to cultured host cells containing recombinant nucleic acid molecules…
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GoTV v. Netflix: Federal Circuit Holds Device-Tailored Content Claims Ineligible Under Section 101
On February 9, 2026, the Federal Circuit issued its decision in GoTV Streaming, LLC v. Netflix, Inc., reversing a jury verdict and holding that three related GoTV patents are invalid under 35 U.S.C. § 101. The panel, in an opinion by Judge Taranto, concluded that the asserted claims were directed to the abstract idea of…
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US Patent No. 7,679,637 v. Google: Federal Circuit Rejects Functional Claims Under Section 101
On January 22, 2026, the Federal Circuit affirmed the dismissal of a patent infringement complaint against Google at the pleading stage, holding that the asserted claims of U.S. Patent No. 7,679,637 are patent-ineligible under 35 U.S.C. § 101. The decision reinforces a familiar theme in modern eligibility jurisprudence: claims drafted at a high level of…
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Optis Cellular Technology v. Apple Inc.: Federal Circuit Orders New Trial on Infringement and Damages Due to Unanimity Violation and Improper Evidence
The Federal Circuit’s June 16, 2025, decision in Optis Cellular Technology, LLC v. Apple Inc., Nos. 2022-1904, 2022-1925, vacates a $300 million damages judgment in a high-stakes standard-essential patent (SEP) case and mandates a new trial on both infringement and damages. The court found that the Eastern District of Texas violated Apple’s constitutional right to…
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United Services Automobile Association v. PNC Bank N.A.: Federal Circuit Invalidates Mobile Check Deposit Patent as Abstract and Non-Inventive
In United Services Automobile Association v. PNC Bank N.A., the Federal Circuit reversed a district court ruling that had upheld the patent eligibility of United Services Automobile Association’s (“USAA”) mobile check deposit patent, holding instead that the asserted claim of U.S. Patent No. 10,402,638 (“the ’638 patent”) was directed to an abstract idea and lacked…
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Recentive v. Fox: Generic Machine Learning in a New Field Is Not Patent Eligible
In Recentive Analytics, Inc. v. Fox Corp., No. 23-2437 (Fed. Cir. Apr. 18, 2025), the Federal Circuit affirmed the dismissal of a patent infringement suit on § 101 grounds, holding that Recentive’s asserted patents were directed to ineligible subject matter. The court concluded that the patents merely applied well-known machine learning techniques to the new…