Patent Law University

37 decisions · Patent law

Patent Eligibility Decisions (35 U.S.C. § 101)

Section 101 limits patents to processes, machines, manufactures and compositions of matter. Abstract ideas, laws of nature and natural phenomena are not eligible on their own, and courts apply the two-step Alice/Mayo test to decide whether a claim adds enough to them.

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  1. Fed. Cir. · Sept. 30, 2026In re Medical Components, Inc.The Federal Circuit denied mandamus. MedComp did not show a clear and indisputable right to relief based on an alleged conflict between the Utah court's post-remand ruling and the mandate in a different AngioDynamics appeal.
  2. Fed. Cir. · Sept. 30, 2026EPIC TECH, LLC v. PEN-TECH ASSOCIATES, INC.The Federal Circuit vacated because the district court did not provide enough reasoning to permit meaningful review of its denial of sanctions and fees. The panel did not decide whether Epic Tech or its counsel violated Rule 11 or whether…
  3. Fed. Cir. · Sept. 25, 2026Receivership Estate of AudienceScience Inc. v. Google LLCThe Federal Circuit affirmed, holding that the asserted claims are directed to the abstract idea of targeting advertisements to internet users to maximize revenue generation and lack an inventive concept. The court also held that…
  4. Fed. Cir. · Sept. 21, 2026BERKELEY*IEOR v. W.W. Grainger Inc.The Federal Circuit held that the asserted claims are patent ineligible because they are directed to the abstract idea of calculating profitability and do not recite an inventive concept. The alleged improvement—parallel processing inside…
  5. Fed. Cir. · Aug. 31, 2026Constellation 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…
  6. Fed. Cir. · Aug. 28, 2026AML IP, LLC v. Bath & Body Works Direct, Inc.The Federal Circuit affirmed, holding that the district court did not abuse its discretion by deciding both improper venue and § 101 eligibility grounds in the same dismissal order. The court also declined to opine on the preclusive…
  7. Fed. Cir. · Aug. 10, 2026iCharts LLC v. Tableau Software, LLCThe Federal Circuit affirmed, holding that the representative claims were directed to the abstract idea of generating and sharing self-contained interactive charts on computers or across websites. The claims added no inventive concept…
  8. Fed. Cir. · July 23, 2026CEIVA OPCO, LLC v. AMAZON.COM, INC.The Federal Circuit held that claim 19 of the ’573 patent was not directed to an abstract idea because it claimed a specific technological improvement: a digital picture frame with a physically separable user interface enabling remote…
  9. Fed. Cir. · July 21, 2026Dental Monitoring SAS v. Align Technology, Inc.The Federal Circuit affirmed the Board’s obviousness determinations. Substantial evidence supported the Board’s findings on the combined prior-art teachings, no teaching away, public accessibility of the Maninis reference, and the…
  10. Fed. Cir. · July 17, 2026Schindler v. SquiresThe Federal Circuit affirmed the district court’s judgment without opinion under Federal Circuit Rule 36. The judgment provides no merits reasoning or identified patent-law issue.
  11. Fed. Cir. · July 7, 2026Dental 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…
  12. Fed. Cir. · July 6, 2026LINFO IP, LLC v. TRUSTPILOT, INC.The Federal Circuit held that the settlement and license ended the Article III controversy between Linfo and Trustpilot. Trustpilot’s reserved right to participate in the appeal did not preserve jurisdiction because Trustpilot no longer…
  13. Fed. Cir. · July 2, 2026ETISON 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…
  14. PTAB · June 22, 2026Light & Wonder, Inc. v. Evolution Malta Ltd.When exceptional circumstances affecting institution arise after institution but before trial has progressed meaningfully—such as a co-pending litigation ruling that all or substantially all challenged claims are invalid—the Director may…
  15. Fed. Cir. · June 4, 2026Arendi S.A.R.L. v. Oath Holdings Inc.The Federal Circuit affirmed, holding that the asserted claims of all four patents, including the '843 patent on an alternative ground, are patent-ineligible under § 101. The claims were directed to the abstract idea of identifying…
  16. Fed. Cir. · June 4, 2026Ollnova Technologies Ltd. v. ecobee Technologies ULCThe Federal Circuit vacated the infringement and damages judgments because the verdict form used a single infringement question for all asserted patents, creating an impermissible risk of a non-unanimous verdict. It also vacated and…
  17. Fed. Cir. · June 2, 2026AGI SureTrack LLC v. Farmers Edge Inc.The Federal Circuit affirmed that the asserted claims are patent ineligible because they are directed to collecting, interpreting, and transmitting farming-operation data using generic computer components, with no inventive concept. The…
  18. Fed. Cir. · May 15, 2026mCom IP, LLC v. City National Bank of FloridaThe Federal Circuit affirmed the Rule 12(b)(6) dismissal with prejudice because mCom showed no error in the district court's obviousness-based invalidity ruling on claim 17. It reversed the § 285 fee award and the § 1927 sanction against…
  19. Fed. Cir. · May 15, 2026mCom IP, LLC v. HSBC Bank USA, N.A.The Federal Circuit affirmed dismissal with prejudice of mCom's infringement complaint on claim 17 of the '508 patent. Issue preclusion from the court's same-day affirmance of claim 17's invalidity in the companion Florida appeal bars the…
  20. Fed. Cir. · May 5, 2026TJTM Technologies, LLC v. Google LLCRepresentative claim 1 of U.S. Patent No. 8,958,853 is directed to the abstract idea of 'screening notifications' and recites only generic, well-known components arranged in a conventional manner, failing both steps of the Alice…
  21. Fed. Cir. · Apr. 29, 2026RFC Lenders of Texas, LLC v. Smart Chemical Solutions, LLCThe Federal Circuit held that the claims of the '471 patent, represented by claim 1, are directed to the abstract idea of detecting, transmitting, and processing data to monitor vehicles and lack an inventive concept, so they are…
  22. Fed. Cir. · Apr. 28, 2026Constellation 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…
  23. Fed. Cir. · Apr. 23, 2026NantWorks, 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…
  24. PTAB · Sept. 26, 2025Ex parte DesjardinsWhen a claim recites an abstract idea (here, a mathematical calculation) at Step 2A, Prong One, but the claim as a whole reflects an improvement to how a machine learning model itself operates, as disclosed in the specification, the claim…
  25. PTAB · Apr. 17, 2025Hulu, LLC v. Piranha Media Distribution, LLCInformative decision only: persuasive authority, not binding precedent. When a district court has already entered a decision finding the challenged claims invalid under 35 U.S.C. § 101 before the Board's institution decision, the Director…
  26. PTAB · May 15, 2019Ex parte FautzInformative decision only: persuasive authority, not binding precedent. Applying the 2019 Revised Patent Subject Matter Eligibility Guidance, when claims recite mathematical formulas (a judicial exception) but the additional elements,…
  27. PTAB · May 15, 2019Ex parte KimizukaInformative decision only: persuasive authority, not binding precedent. Applying the 2019 Revised Patent Subject Matter Eligibility Guidance, when a claim recites a judicial exception (here, a mental process) and its additional elements…
  28. PTAB · Apr. 1, 2019Ex parte HannunInformative decision only: persuasive authority, not binding precedent. Applying the 2019 Revised Patent Subject Matter Eligibility Guidance, when a claim recites a specific implementation of speech transcription (normalizing, jitter set,…
  29. PTAB · Apr. 1, 2019Ex parte SavescuInformative decision only: persuasive authority, not binding precedent. Applying the 2019 Revised Patent Subject Matter Eligibility Guidance, the Board held that when a claim recites a judicial exception (here, a method of organizing…
  30. PTAB · Mar. 25, 2019Ex parte OlsonInformative decision only: persuasive authority, not binding precedent. Applying the USPTO's January 7, 2019 2019 Revised Patent Subject Matter Eligibility Guidance, when a claim recites a mathematical concept (Step 2A, Prong 1) but the…
  31. PTAB · Feb. 1, 2019Ex parte SmithInformative decision only: persuasive authority, not binding precedent. Applying the January 7, 2019 Memorandum (2019 Revised Patent Subject Matter Eligibility Guidance), when a claim recites a judicial exception (here, the fundamental…
  32. PTAB · Jan. 18, 2019Amazon.com, Inc. v. Uniloc Luxembourg S.A.When a patent owner files a motion to amend under 35 U.S.C. § 316(d) in an inter partes review, the Board may consider, and a petitioner may raise in opposition, grounds of unpatentability other than § 102 and § 103, such as § 101,…
  33. PTAB · Dec. 15, 2016Kayak Software Corp. v. Int’l Bus. Mach. Corp.Informative decision only: persuasive authority, not binding precedent. When the same or substantially the same prior art or arguments were previously presented to the Office during a long, exhaustive prosecution, and the petitioner shows…
  34. PTAB · May 14, 2015Westlake Servs., LLC v. Credit Acceptance Corp.When a covered business method patent review results in a final written decision addressing only the claims on which trial was instituted, estoppel under 35 U.S.C. § 325(e)(1) and 37 C.F.R. § 42.73(d)(1) applies on a claim-by-claim basis,…
  35. PTAB · May 8, 2013Ex parte MewherterWhen a claim recites a "machine-readable storage medium" (or computer-readable storage medium), the specification is silent as to its meaning, and extrinsic evidence shows that those of ordinary skill at the effective filing date…
  36. PTAB · Jan. 28, 2008Ex parte NehlsWhen a claim to a computer-based system differs from the prior art system only in the content of the sequence data stored in its data storage means, and that data does not functionally change how the computer performs the search (the…
  37. PTAB · Jan. 31, 1996Ex parte BhideWhen a specification states a utility (or "how to use") that corresponds in scope to the claimed subject matter, it must be taken as sufficient under 35 U.S.C. § 101 and the first paragraph of § 112 unless one skilled in the art has…

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