Constellation Designs, LLC v. LG Electronics Inc.

Constellation Designs, LLC v. LG Electronics Inc. The Federal Circuit held that the asserted '761 and '700 patent optimization claims are patent-ineligible because they claim the result-oriented abstract idea of optimizing a constellation for parallel-decode capacity without reciting how to do so, but held that the asserted '509 and '922 patent constellation claims are eligible because they claim specific non-uniform constellations. The court also held that Constellation could prove some claim limitations through standards evidence and others through product evidence, and that the damages expert had a sufficient comparability basis for built-in apportionment. The decision draws a practical § 101 line between broadly claiming an optimization result and claiming specific technical constellation implementations, while also approving limitation-by-limitation use of standards evidence to prove infringement. Vacated-in-part, affirmed-in-part, and remanded. The court vacated the summary judgment of eligibility for claims 17, 21, 24, and 28 of the '761 patent and claim 5 of the '700 patent; affirmed eligibility for claims 21 and 23 of the '509 patent and claims 24 and 44 of the '922 patent; affirmed denial of JMOL of non-infringement and no damages; and affirmed denial of LG's motion to exclude the damages expert. On § 101, the court separated the claims into optimization claims and constellation claims; the optimization claims recited a QAM constellation optimized for parallel-decode capacity but did not claim the optimization process or meaningful constraints. Relying on Morse and ChargePoint, the court treated the optimization claims as result-oriented and preemptive; the claimed inventive concept was the abstract idea itself, not an additional claim element or ordered combination. The constellation claims survived Alice step one because they recited specific non-uniform constellations, including overlapping constellation point locations, as a concrete implementation addressing capacity/coding-gain constraints. On infringement, the court held that Fujitsu permits a patentee to use industry-standard evidence on a limitation-by-limitation basis, so long as the relevant standard provisions necessarily practice the limitation and are mandatory or shown to be implemented. On damages, the court affirmed because the challenge was essentially a Daubert admissibility attack, and the record supported the damages expert's reliance on Zenith licenses as sufficiently comparable for built-in apportionment; LG forfeited a damages-vacatur argument first raised at oral argument. § 101 infringement damages remand waiver / forfeiture precedential § 101 infringement damages remand waiver / forfeiture precedential § 101 infringement damages remand