RECENTIVE ANALYTICS, INC. v. FOX CORP.
Before Dyk, Prost, and Goldberg. Appeal from the United States District Court for the District of Delaware.
Summary: The Federal Circuit found that claims applying established methods of machine learning to a new environment were patent ineligible under 35 U.S.C. § 101.
Recentive sued Fox, alleging infringement of four patents. Two of the patents were the “Machine Learning Training” patents, which concerned scheduling live events. The other two patents were the “Network Map” patents, which concerned creating network maps for broadcasters. Fox moved to dismiss, alleging the asserted claims were patent ineligible under § 101. Applying the two-step Alice inquiry, the district court found the asserted claims were directed to abstract ideas (live event scheduling, network map creation) and did not include an “inventive concept” that made them patent eligible. Therefore, the district court granted Fox’s motion to dismiss. Recentive appealed.
The Federal Circuit affirmed. Under Alice step one, the Federal Circuit explained the patents relied on generic machine learning to perform the claimed methods. The court emphasized Recentive’s admissions that it was not claiming machine learning itself nor any technological improvement to machine learning. The court also rejected Recentive’s argument that applying machine learning to a new environment made its claims patent eligible. As the court explained, limiting an abstract idea to a particular field of use, applying existing technology to a new database, and performing existing tasks faster and more efficiently do not create patent eligibility.
Under Alice step two, Recentive argued its claims recite the inventive concept of “using machine learning to dynamically generate optimized maps and scheduled based on real-time data and update them based on changing conditions.” However, the Federal Circuit agreed with the district court that the asserted claims do no more than claim the abstract idea itself. Accordingly, the Federal Circuit held the asserted claims lacked an “inventive concept” sufficient to transform the claims into patent-eligible subject matter.
Editor: Sean Murray
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