NantWorks, LLC v. Niantic, Inc.

NantWorks, LLC v. Niantic, Inc. The Federal Circuit affirmed that asserted claims of both the '518 patent (directed to mapping and rendering AR objects based on device location using tessellated tile maps) and the '051 patent (directed to selecting and altering AR objects based on device location and context) are patent-ineligible under § 101 as directed to abstract ideas with no inventive concept. Under Alice/Mayo step one, the '518 claims are directed to 'providing information based on a location on a map' and the '051 claims to 'receiving information about a location and displaying materials based on that information'; under step two, neither patent's claims supply an inventive concept beyond those abstract ideas. Reinforces that AR-specific claim language—tessellated tiles, virtual element attributes, altered AR object presence—does not rescue location-based information-display claims from § 101 invalidity when the underlying concept remains providing or filtering information based on location, and that unclaimed specification benefits cannot substitute for an inventive concept in the claims themselves. Affirmed Alice/Mayo step one: Both patents' claims reduce to location-based information filtering and display—an abstract idea—regardless of AR-specific terminology; limiting an abstract idea to the AR field of use does not confer eligibility. Alice/Mayo step two: The court rejected NantWorks's 'selective memory population' argument for the '518 patent because the word 'selectively' does not appear in the claims; unclaimed specification advantages cannot supply an inventive concept. For the '051 patent, the court found NantWorks's expert testimony (Dr. Turk) insufficient to create a genuine factual dispute at step two because the cited paragraphs were either conclusory, repeated unclaimed specification passages, or described abstract benefits rather than identifying an inventive concept within the claims. The 'pencil and paper' test applied to '518 claim 7: each claimed step (locate on map, identify relevant area, display content as overlay) could be performed manually, confirming abstraction. This is a nonprecedential disposition; readers should treat it as illustrative of how the court applies existing § 101 doctrine to AR/location-based patents rather than as binding authority. § 101 claim construction non-precedential remand § 101 non-precedential § 101 non-precedential