Late yesterday, the Federal Circuit released a nonprecedential order dismissing an appeal. This morning, the Federal Circuit released a precedential opinion in a patent case on appeal from the District of Delaware. Here is an introduction to the opinion and link to the order.
Recentive Analytics, Inc. v. Fox Corp. (Precedential)
This case presents the question of patent eligibility of four patents directed to the use of machine learning. The patents claim the use of machine learning for the generation of network maps and schedules for television broadcasts and live events.
Appellant Recentive Analytics, Inc. (“Recentive”), the owner of the patents, sued appellees Fox Corp., Fox Broadcasting Company, LLC, and Fox Sports Productions, LLC (collectively, “Fox”) for infringement. The district court dismissed, concluding that the patents were directed to ineligible subject matter under 35 U.S.C. § 101. We affirm because the patents are directed to the abstract idea of using a generic machine learning technique in a particular environment, with no inventive concept.