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CAFC-DCTJuly 7, 2026·24-2270·Affirmed.

Dental Monitoring SAS v. Align Technology, Inc.

District Court

Holding

The Federal Circuit affirmed summary judgment that the asserted claims are patent-ineligible under § 101. The claims were directed to abstract ideas of acquiring, analyzing, and reporting image information, and reciting a generic deep learning device trained on dental images did not supply an inventive concept.

Why It Matters

The decision reinforces that applying generic machine-learning tools to a new medical or dental imaging context, including with domain-specific training data, may not be enough for eligibility under Alice.

Full Summary

Dental Monitoring SAS v. Align Technology, Inc. The Federal Circuit affirmed summary judgment that the asserted claims are patent-ineligible under § 101. The claims were directed to abstract ideas of acquiring, analyzing, and reporting image information, and reciting a generic deep learning device trained on dental images did not supply an inventive concept. The decision reinforces that applying generic machine-learning tools to a new medical or dental imaging context, including with domain-specific training data, may not be enough for eligibility under Alice. Affirmed. The claims covered using a cellphone or acquisition device to capture dental-arch or aligner images, analyze them with a trained deep learning device, and provide results or guidance. At Alice step one, the court treated the claims as part of the Electric Power Group line: collecting information, analyzing it, and displaying or sending results. The claimed “deep learning device” did not change the eligibility analysis because the specifications described conventional neural-network options, and the claimed training on more than 1,000 dental images was considered inherent to machine learning rather than a technological improvement. At Alice step two, the court found no inventive concept; using generic machine-learning components to perform orthodontic assessment more efficiently did not make the claims significantly more than the abstract idea. The court affirmed invalidity of claims 1 and 14 of the '248 patent and claims 1, 7, and 12 of the '409 patent under § 101. § 101 infringement non-precedential § 101 infringement non-precedential § 101 non-precedential

Key Points

  • The claims covered using a cellphone or acquisition device to capture dental-arch or aligner images, analyze them with a trained deep learning device, and provide results or guidance.
  • At Alice step one, the court treated the claims as part of the Electric Power Group line: collecting information, analyzing it, and displaying or sending results.
  • The claimed “deep learning device” did not change the eligibility analysis because the specifications described conventional neural-network options, and the claimed training on more than 1,000 dental images was considered inherent to machine learning rather than a technological improvement.
  • At Alice step two, the court found no inventive concept; using generic machine-learning components to perform orthodontic assessment more efficiently did not make the claims significantly more than the abstract idea.
  • The court affirmed invalidity of claims 1 and 14 of the '248 patent and claims 1, 7, and 12 of the '409 patent under § 101.
§ 101infringementnon-precedential

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