Constellation Designs, LLC v. LG Electronics Inc.

Constellation Designs, LLC v. LG Electronics Inc. The Federal Circuit held the "optimization" claims (claims 17, 21, 24, 28 of the '761 patent and claim 5 of the '700 patent) ineligible under § 101 as result-oriented claims directed to the abstract idea of optimizing a constellation for PD capacity, but held the "constellation" claims of the '509 and '922 patents eligible. It affirmed denial of JMOL of non-infringement and of no damages, and denial of the motion to exclude the damages expert; vacated in part, affirmed in part, and remanded. The decision applies Morse and ChargePoint to separate result-oriented functional claims (ineligible) from claims reciting specific structures or specific constellations (eligible) in a technical field. It also confirms that standards-based infringement proof may proceed limitation by limitation under Fujitsu. Vacated-in-part, affirmed-in-part, and remanded. Constellation won summary judgment of eligibility on all asserted claims in E.D. Tex. A jury then found the claims not invalid and willfully infringed by LG's ATSC 3.0-compatible televisions, and awarded $1,684,469 based on a $6.75 per-television royalty. Optimization claims (e.g., '761 claim 17): the claims recite a constellation 'optimized for capacity using parallel decode capacity' that achieves a reduced SNR compared to dmin-maximizing constellations, but not how to optimize. The court called the issue close but held the claims directed to the abstract idea of optimizing, analogous to Morse and ChargePoint. It would not import the specification's iterative process into the claims. Step two for the optimization claims: Constellation's asserted inventive concept was the abstract idea itself. Its reliance on novelty, nonobviousness, and efficiency gains conflated §§ 102/103 with the inventive-concept inquiry. The court vacated eligibility for these claims and remanded. Constellation claims ('509 claims 21, 23; '922 claims 24, 44): the claims recite specific non-uniform constellations, for example unequally spaced points with overlapping locations. They are a concrete technological solution to a capacity problem and are not directed to an abstract idea, so step two was not reached. The court affirmed eligibility, noting that even LG agrees these claims do not recite optimization. Infringement and damages: Fujitsu permits proving individual limitations via a standard, if the relevant portion is sufficiently specific and mandatory or shown to be implemented, while proving other limitations with product evidence. Substantial evidence supported the verdict. LG's damages attack on the Zenith licenses and built-in apportionment was really an inadmissibility challenge, improper under JMOL and unsupported on the Daubert record. LG's oral-argument request to vacate damages was forfeited and, alternatively, unpersuasive. § 101 infringement damages remand claim construction waiver / forfeiture precedential