IP Law Daily, PATENT—D. Del.: Nokia withstands eligibility challenge to video-encoding patents; infringement suit against Warner proceeds, (Mar 6, 2026)

By Steven D. Cole, J.D.

Two of the challenged patents survived the motion because they presented inventive concepts, and the third was not directed to an abstract idea, but a novel concept.

A motion to partially dismiss infringement claims filed by Nokia Technologies Oy has been denied by the federal district court for the District of Delaware. Defendants Warner Brothers Entertainment Inc., Warner Brothers Discovery, Inc., and Home Box Office, Inc. (collectively, Warner Bros.) responded to Nokia’s infringement suit by arguing that all of the claims forming the three patents at issue were directed to ineligible subject matter, and therefore not patentable under 35 U.S.C. § 101. Two of the challenged patents, however, each contained an inventive concept sufficient to transform what were abstract ideas into patent-eligible applications. The third patent was directed to a novel and unconventional technological improvement (Nokia Technologies Oy v. Warner Bros. Entertainment Inc., No. 1:25-cv-01337-GBW (D. Del. Mar. 5, 2026)).

Background. Nokia commenced this action against Warner Bros. on November 1, 2025, alleging the latter’s infringement upon U.S. Patent Nos. 8,050,321 (’321 Patent), 6,968,001 (’005 Patent), and 6,950,469 (’469 Patent). The ’321 Patent, which contains 11 claims, is generally directed to “[a] method for encoding a video sequence.” The ’005 Patent, which has 46 claims, is generally directed to “[a] method of encoding a video signal representing a sequence of pictures.” The ’469 Patent, consisting of 51 claims, is generally directed to “[a] method of interpolation in video coding.” Warner Bros. moved to partially dismiss the suit, asserting that all of the challenged patents’ claims were directed to ineligible subject matter.

Patent eligibility. In Alice Corp. v. CLS Bank International, 573 U.S. 208 (2014), the United States Supreme Court established a two-step framework for determining patent eligibility under 35 U.S.C. § 101. First, a court must ascertain whether the claims at issue are directed to a patent-eligible concept, and not, inter alia, an abstract idea. If the claims do not pass Step One, the patent may still qualify for eligibility at Step Two if the claim elements, both individually and as an ordered combination, present an inventive concept.

Claims are representative. As a threshold issue, the court first determined that claim 1 of each Patent was representative of its respective Patent.

The ’321 and ’005 Patents. With regard to the ’321 and ’005 Patents, the court agreed with Warner Bros. that each claim 1 was directed toward the abstract idea of organizing data by numbering certain image frames, and not an improvement in the functioning of video-playback technology or encoder/decoder schemes. Step Two of the Alice analysis, though, revealed that each Patent presented an inventive concept. The ’321 Patent carved out a specific method of sequencing image frames—a previously unknown technological benefit—by providing end-users with the ability to start browsing a video sequence from an arbitrary position in a file, rather than at the beginning of the video. The ’005 Patent likewise contained an inventive concept with regard to the unconventional manner in which image frames are numbered—namely, the specific sequencing of reference pictures without regard to non-reference pictures. In prior art decoder schemes, there was no means of detecting whether a reference picture had been lost.

The ’469 Patent. At Alice Step One, the court determined that the ’469 Patent was not directed to an abstract idea; rather, it was directed to novel and unconventional improvements to motion-compensated prediction in the field of digital video coding. At the time the ’469 Patent was filed, video compression standards reduced temporal redundancy by predicting the content of some frames from others in a video sequence using many layers of unnecessary calculations and stored results. The ’469 Patent addressed this problem by outlining, mathematically, how to interpolate certain values more selectively, thereby reducing the number of calculations required to obtain the needed values.

The Case is No. 1:25-cv-01337-GBW.

Judge: Williams, G.

Attorneys: Brian E. Farnan (Farnan LLP) for Nokia Technologies Oy. Jennifer Ying (Arsht & Tunnell LLP) for Warner Bros. Entertainment Inc.

Companies: Nokia Technologies Oy; Warner Bros. Entertainment Inc.

Cases: Patent DelawareNews GCNNews