IP Law Daily, PATENT—E.D. Tex.: Object-detection patents did not succumb to invalidity challenges, (Jun 11, 2026)

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

The district court found that asserted patents disclosing various object detection methods for video and image processing systems were not invalid.

The federal district court in Texas denied judgment on the pleadings regarding three patents directed to various object detection methods for video and image processing systems. The district court found that the patent claims either were not directed to abstract ideas at Alice step one or that the patent owner raised plausible factual allegations of unconventionality sufficient to survive at Alice step two (NEC Corp. v. Anker Innovations Technology Co., Ltd., No. 2:24-cv-00720-JRG (E.D. Tex. Jun. 4, 2026)).

NEC Corporation (NEC) sued Anker Innovations Technology Co., Ltd., and Anker Innovations Ltd. (collectively, Anker), accusing them of infringing six U.S. patents that disclose various object detection methods for video and image processing systems. NEC alleged that Anker’s smart doorbell products infringe these patents. Anker filed a motion for judgment on the pleadings (motion) that challenged four of these patents: U.S. Patent Nos. 9,953,240 (’240 Patent); 10,037,467 (’467 Patent); 11,210,526; (’526 Patent); and 11,537,814 (’814 Patent) pursuant to Federal Rule of Civil Procedure 12(c), contending that the asserted claims of the ’240, ’467, ’526, and ’814 Patents are patent-ineligible under 35 U.S.C. § 101. NEC then dropped the ’240 Patent from the case and updated its allegations specifying that it is asserting claims for the remaining three patents.

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.

’467 Patent. Anker contended that claim 1 of the ’467 Patent was directed to an abstract idea of detecting and tracking features of an object in images and associating information with the features or a series of data collection, data manipulation, and data organization steps that are routinely invalidated. The court disagreed that claim 1 of the ’467 Patent was directed to the abstract idea of “detecting and tracking features of an object in images and associating information with the features,” as Anker specified. The court also noted that Anker’s security guard example was unavailing because it oversimplifies the technical solution of claim 1 by explaining that a security guard could have detected and tracked certain features (e.g., various hats in a video) based on quantity and a selection criterion to find a frame number. The claimed detection, extraction, selection, and association process, however, is far more nuanced, such that Anker’s analogy does not support that claim 1 is directed to an abstract idea. Moreover, the claimed process for detecting objects and quantifying different object elements in a video to make frame selections and associations therefrom based on a selection criterion lacks a true human analog.

The court noted that the asserted claims of the ’467 Patent instead focussed on a specific detection, extraction, selection, and association process to improve the functionality of an image processing system, rather than on an abstract image processing idea for which computers are invoked merely as a tool. Therefore, the court found that claim 1 of the ’467 Patent was not directed to an abstract idea. However, even assuming arguendo that claim 1 was directed to an abstract idea, NEC raised plausible factual allegations at Alice step two which foreclosed granting Anker’s motion for the ’467 Patent.

’526 Patent. Anker contended that the ’526 Patent asserted claims were directed to the abstract idea of “categorizing portions of images in order to accumulate data.” NEC responded saying that the ’526 Patent claims were directed to a specific technique of analysing images that are captured from a surveillance camera. The court agreed with Anker that the ’526 Patent claims are directed to the abstract idea of “labeling data to train a machine learning model,” and found aligning with precedent from the Federal Circuit’s decision in Recentive Analytics, Inc. v. Fox Corp., 134 F.4th 1205 (Fed. Cir. 2025), that “the very nature of machine learning” includes using “selected training material.” However, at Alice step two, NEC raised plausible factual allegations that features of claim 1, when considered individually or collectively, were unconventional.

’814 Patent. Anker contended that the ’814 Patent asserted claims were directed to the abstract idea of “using machine learning to identify objects in data and transmit data based on the identification.” NEC claimed that the ’814 Patent claims were directed to a system for easily collecting data that can contribute to the generation of a model with high identification accuracy. The claims allegedly specified “specific elements” that in combination were “directed to specific techniques for improving computer technology.” The court agreed with Anker that the ’814 Patent asserted claims were directed to an abstract idea. Specifically, the court found that the asserted claims were directed to the general idea of “using machine learning to identify objects in data and selecting training data.” At Alice step two, NEC made specific allegations that features of claim 1 of the ’814 Patent, when considered individually or collectively, were unconventional.

Therefore, the court concluded that the ’467 Patent claims were not abstract, and the ’526 and ’814 Patent claims, while directed to abstract ideas, survived at Alice step two because NEC pleaded plausible factual allegations of unconventionality that cannot be resolved on the pleadings. Accordingly, judgment on the pleadings was denied.

The Case is No. 2:24-cv-00720-JRG.

Judge: Gilstrap, R.

Attorneys: Saqib Javaid Siddiqui (Mayer Brown, LLP) for NEC Corp. T. Vann Pearce, Jr. (Orrick, Herrington & Sutcliffe LLP) for Anker Innovations Technology Co., Ltd.

Companies: NEC Corp.; Anker Innovations Technology Co., Ltd.

Cases: Patent TechnologyInternet TexasNews