IP Law Daily, PATENT—D. Ariz.: Patent for automated resume search systems was invalid, (Sep 3, 2026)

By Carolin Dennis, B.Sc., LL.B., LL.M.

The patent claims covered an abstract idea and lacked an inventive concept.

A patent related to automated resume search systems that extract terms from job descriptions and assigned numerical values to create search queries was directed to an abstract idea of collecting and synthesizing data and lacked an inventive concept, the federal district court in Phoenix, Arizona, has held. As a result, the district court granted ZipRecruiter Incorporated’s motion to dismiss Linfo IP LLC’s patent infringement lawsuit (Linfo IP LLC v. ZipRecruiter Inc., No. 2:25-cv-03718-DJH (D. Ariz. Aug. 26, 2026)).

Linfo IP LLC (Linfo) was the owner of U.S. Patent No. 9,665,641 (the ’641 patent) that relates to novel and improved systems and methods for conducting electronic commerce. In all, patent 641 comprises 20 claims (claims 1–20), all related to how this query-based interface works and slicing the method used to extract terms from a resume and job description document further and further. Linfo filed a complaint alleging that ZipRecruiter Incorporated (ZipRecruiter) infringed the ’641 patent by offering up its exact invention to its consumers. Linfo attached to its complaint an exhibit showing how ZipRecruiter’s search query box allows it users to upload their resumes, produce a certain search query phrase or terms, and then match it against a job description repository. ZipRecruiter moved to dismiss the complaint.

ZipRecruiter argued that Claim 8 is the representative claim for all claims that are alleged to be patented by Linfo because although Linfo says that claims 1–20 encompass the entirety of the ’641 patent, it has only attached exhibits purporting to show infringing activity related to Claim 8. Further, ZipRecruiter argued that the idea of a tabulated searchable database query and query format is not a patentable idea under Alice step one. Additionally, as Claim 8 is directed towards an abstract idea, ZipRecruiter contended that the district court must also find that Claim 8 stalls at Alice step two. Linfo argued that its other claims are independent of Claim 8 and add a distinctive technological component to the patent overall. However, the district court found that Claim 8 engulfs the other claims at issue and determined that Claim 8 will be the representative claim.

Patent eligibility. The district court used the two-step inquiry under Alice to determine whether the patent claim is an abstract idea.

Alicestep one. The district court noted that Linfo extracts information from resumes and job description documents and assigns them to a coefficient and numeric value and says that it then creates special search queries with that information. However, combining and synthesizing data from various sources and altering its presentation but not its character, is within the realm of abstract ideas. Citing Enfish, LLC v. Microsoft Corp., 822 F.3d 1327 (Fed. Cir. 2016), the district court emphasized that for something to not be classified as an abstract idea, it must improve computer capabilities instead of merely the computer as a tool in its overall process. With no improvement to computer capabilities present here, the district court concluded that Linfo’s Claim 8 is simply an abstract idea. Therefore, at Alice step one, the district court determined that Claim 8 is an abstract patent-ineligible idea.

Alicestep two.Alice step two asks whether the claims, despite being directed to an abstract idea, nonetheless contain an inventive concept that transforms the nature of the claim into a patent-eligible application of the abstract idea.

The district court noted that computer and network components only feature in so far as what the compiled database and search queries are used on, and nothing more was alleged by Linfo. Linfo argued that “curated lexicons of importance-indicating verbs/adjectives and map them to specific numeric coefficient” adds the transformative component required for Claim 8 to be inventive under Alice step two. However, besides reiterating the abstract idea that is patent-ineligible, Linfo has failed to show how the concept of creating a database by extracting terms from documents is inventive. Citing Teradata US, Inc. v. SAP SE, 2021 WL 6332792, (N.D. Cal. Oct. 5, 2021) the district court noted that relying on conventional computer and network methods is not a persuasive showing under Alice step two. Therefore, the district court determined that Claim 8 is not inventive under Alice step two.

Accordingly, the district court concluded that Claim 8 is patent-ineligible, and that ZipRecruiter’s motion to dismiss should be granted.

The Case is No. 2:25-cv-03718-DJH.

Judge: Humetewa, D.

Attorneys: Andrew Ling (Andrew M. Ling PC) for Linfo IP LLC. Michael Zinna (Kelley Drye & Warren LLP) for ZipRecruiter Inc.

Companies: Linfo IP LLC; ZipRecruiter Inc.

Cases: Patent ArizonaNews TechnologyInternet