ETISON LLC v. HIGHLEVEL, INC.

ETISON LLC v. HIGHLEVEL, INC. The Federal Circuit affirmed, holding that all asserted claims are invalid under § 101 because they add no inventive concept to the unchallenged abstract idea. The district court erred in treating one claim as representative of all claims without adequately addressing dependent claims reciting “one or more triggers,” but the error was harmless because those limitations also lacked an inventive concept. The decision reinforces that patentees opposing early § 101 motions must do more than identify claim differences or allege technical benefits in conclusory terms; they need a non-frivolous, claim-specific reason why additional limitations matter to eligibility. Affirmed dismissal for failure to state a claim. ClickFunnels did not challenge Alice step one on appeal, leaving in place the conclusion that the claims are directed to the abstract idea of filtering information based on user preferences to arrive at a final result. The Federal Circuit found error in the representative-claim analysis because the district court did not adequately address whether dependent claims with “one or more triggers” were fairly represented by claim 1 of the ’357 patent. That error was harmless because the district court effectively analyzed the trigger limitations at Alice step two, and the Federal Circuit agreed they were conventional user-action-triggered events. Allegations of reduced processing power, bandwidth, and computing resources were treated as conclusory because the claims, specification, and complaint did not explain how the claimed website templates, directional webpages, or triggers achieved a technical improvement. The court affirmed invalidity of all claims and the Rule 12(b)(6) dismissal. § 101 waiver / forfeiture non-precedential § 101 waiver / forfeiture non-precedential § 101 non-precedential