IP Law Daily, PATENT—D. Del.: Infringement case dismissed after patent for youth banking app ruled invalid, (Jul 30, 2026)

By Brian Craig, J.D.

The patent that merely filters content on a telephone based on user’s location is an abstract idea and not an inventive concept eligible for patentability.

Concluding that the claims for a patent for a phone app based on the user’s location is not eligible for patent protection, the federal district court in Delaware has dismissed a patent infringement suit brought by Lab Technology LLC against Greenlight Financial Technology, Inc. The court concluded that the patent claims for a display based on that telephone’s location is directed to a patent-ineligible abstract idea. The court also concluded that the patent that merely claims the abstract idea of filtering content on a set of generic computer components is not an inventive concept eligible for patentability (Lab Technology LLC v. Greenlight Financial Technology, Inc., No. 1:25-cv-01356-JCB (D. Del. Jul. 23, 2026)).

Lab Technology LLC owns U.S. Patent No. 9,219,982 (the ’982 Patent) entitled “Apparatus and Method for Automatically Refreshing a Display of a Telephone.” Lab Technology filed suit against Greenlight Financial Technology, Inc. (“Greenlight Financial”) alleging that the company’s banking app infringes claim 13 of the ’982 Patent. Greenlight Financial operates a “Kids & Teen Banking App” that teaches children how to manage their finances. Claim 13 of the ’982 Patent claims a method of refreshing a display panel of a telephone, comprising a display panel, a processor, and a datastore comprising at least one function comprising information relating to a current location of the telephone and a user of the telephone. Greenlight Financial moved to dismiss the complaint. After Lab Technology amended the complaint, Greenlight Financial moved to dismiss the amended complaint based on prosecution disclaimer and patent-ineligible subject matter.

Prosecution disclaimer. The court first examined prosecution disclaimer and whether the patentee disavowed the claim interpretation. Where the patentee has unequivocally disavowed a certain meaning to obtain their patent, the doctrine of prosecution disclaimer attaches and narrows the ordinary meaning of the claim congruent with the scope of the surrender. Prosecution disclaimer precludes patentees from recapturing through claim interpretation specific meanings disclaimed during prosecution. In this case, the court found that the applicant distinguished the remote “location server” from the self-contained location tracking in the prior art. Thus, the court declined to dismiss the case based on prosecution disclaimer.

Abstract idea. Next, the court examined whether the patent claims are an abstract idea eligible for patent protection. Under Alice step one, the court determines whether a claim is directed to a patent-ineligible concept, such as an abstract idea. Here, in essence, the patented method teaches displaying different content on a telephone based on that telephone’s location. The U.S. Court of Appeals for the Federal Circuit has consistently held such claims to be directed to a patent-ineligible abstract idea. Mere automation of manual processes using generic computers does not constitute a patentable improvement in computer technology. Therefore, the patent claims cover an abstract idea and are ineligible for patent protection under step one.

Inventive concept. The court also held that the patent claims do not contain an inventive concept for patentability under step two. Under Alice step two, the court considers whether the claims contain an inventive concept that is “sufficient to ensure that the patent in practice amounts to significantly more than a patent upon the ineligible concept itself. In this case, the court found that the’982 Patent merely claims the abstract idea of filtering content on a set of generic computer components. Other courts have previously held that filtering and displaying content based on location via generic computer components claims an abstract idea and does not otherwise claim an inventive concept.

Leave to amend. Finally, the court denied leave to amend the complaint. The patentee already amended the complaint once. Given that the court’s holding of invalidity is based on the ’982 Patent’s claims and specification, amendment would be futile. Therefore, the court dismissed the case with prejudice.

The Case is No. 1:25-cv-01356-JCB.

Judge: Barker, J.

Attorneys: Brian E. Lutness (Silverman, McDonald & Friedman) for Lab Technology LLC. Gregory Erich Stuhlman (Chipman Brown Cicero & Cole, LLP) for Greenlight Financial Technology, Inc.

Companies: Lab Technology LLC; Greenlight Financial Technology, Inc.

Cases: Patent DelawareNews TechnologyInternet