IP Law Daily, PATENT—D. Del.: Video technology company’s infringement lawsuit dismissed, patents found invalid, (May 28, 2026)

By Saurabh Kashyap, B.A., LL.B., LL.M.

The asserted patents were directed to abstract ideas involving the organization and display of video content and lacked any inventive concept sufficient to confer patent eligibility under Alice.

A federal district court in Delaware has dismissed a patent infringement lawsuit brought by a video technology company against a digital media technology company after holding that the two asserted patents, directed to interactive video streaming and customizable product videos, claimed patent-ineligible subject matter under 35 U.S.C. § 101. The court concluded that both patents merely implemented abstract ideas using generic computer technology and failed to disclose any specific technological improvement to computer functionality. Granting the defendant’s dismissal motion, the court dismissed the action with prejudice and held that amendment would be futile because the defects arose from the patents themselves rather than the pleadings (JBF Interlude 2009 Ltd. v. Artisan Technologies LLC, No. 1:25-cv-01553-JCB (D. Del. May 26, 2026)).

Background. The plaintiff, JBF Interlude 2009 Ltd., develops interactive video and digital media technologies. The defendant, Artisan Technologies LLC, is a digital media technology company. The dispute arose from alleged infringement of patents relating to video streaming and customizable interactive product videos.

The plaintiff asserted U.S. Patent No. 9,641,898 (the ’898 patent), titled “Methods and Systems for In-Video Library,” and U.S. Patent No. 12,450,306 (the ’306 patent), titled “Video Player Integration Within Websites.” The ’898 patent covered systems, allowing users to insert selected prerecorded video segments into an uninterrupted video stream. The ’306 patent related to interactive product videos embedded in webpages that dynamically changed according to user-selected product features.

The plaintiff sued Artisan for direct and indirect infringement of both patents. Artisan moved to dismiss under Rule 12(b)(6), arguing that the patents claimed ineligible subject matter under § 101.

Court’s analysis. Applying the two-step framework established in Alice Corp. v. CLS Bank International, 573 U.S. 208 (2014), the court examined whether the claims were directed to abstract ideas and whether they contained an inventive concept sufficient to transform those ideas into patent-eligible subject matter.

The ’898 patent. The court concluded that the ’898 patent was directed to the abstract idea of “collecting, organizing, and automatically displaying a playlist of video segments.” The patent described a video player that streamed prerecorded video segments, allowing users to select additional videos from a library and add them to a watchlist for seamless playback.

The court found that neither the claims nor the specification disclosed any technological improvement to streaming hardware or software. Instead, the specification repeatedly stated that the invention could operate using “any appropriate hardware or software,” “any suitable programming language,” and “any suitable network.”

Rejecting the plaintiff’s argument that the patent improved seamless playback through a “predefined content path,” the court held that the specification described “seamless” playback only in result-oriented terms without identifying any concrete technological mechanism. Citing Bluebonnet Internet Media Services, LLC v. Pandora Media, LLC, 2024 WL 1338940 (Fed. Cir. Mar. 29, 2024), the court explained that methods for organizing digital media playlists based on user selections constitute abstract ideas.

At Alice step two, the court held that the ’898 patent lacked an inventive concept. Citing GoTV Streaming, LLC v. Netflix, Inc., 166 F.4th 1053 (Fed. Cir. 2026), the court emphasized that only claimed features, not unclaimed details appearing in the specification, can supply an inventive concept.

The ’306 patent. The court similarly found that the ’306 patent was directed to the abstract idea of displaying products with shopper-selected features. The patent disclosed a system in which users selected configurable product features through webpage interface elements, causing a video player to update the displayed product accordingly.

The court analogized the claimed invention to a salesperson in a physical store responding to customer requests for different product configurations. Citing University of Florida Research Foundation, Inc. v. General Electric Co., 916 F.3d 1363 (Fed. Cir. 2019), the court characterized the patent as a quintessential “do it on a computer” claim.

The plaintiff argued that the patent solved an “Internet-specific problem” through a message-passing architecture between an application layer and a video player layer. The court rejected that argument because the claims did not explain how the messaging architecture improved computer technology itself. Relying on Customedia Technologies, LLC v. Dish Network Corp., 951 F.3d 1359 (Fed. Cir. 2020), the court held that improving user experience alone does not amount to an improvement in computer functionality.

The court also held that the ’306 patent lacked an inventive concept because the specification admitted that the invention could be implemented using generic hardware, software, networks, and programming languages.

Conclusion. Having determined that both asserted patents were invalid under § 101, the court declined to address Artisan’s alternative arguments challenging the sufficiency of the infringement allegations and dismissed the action with prejudice.

The Case is No. 1:25-cv-01553-JCB.

Judge: Barker, J.

Attorneys: David Ellis Moore (Potter Anderson & Corroon, LLP) for JBF Interlude 2009 Ltd. Andrew Russell (Shaw Keller LLP) for Artisan Technologies LLC.

Companies: JBF Interlude 2009 Ltd.; Artisan Technologies LLC

Cases: Patent DelawareNews TechnologyInternet