IP Law Daily, PATENT—Fed. Cir.: Dismissal of patent infringement lawsuit against Amazon affirmed, (Feb 26, 2026)

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

District court correctly found that Rensselaer’s artificial intelligence-related patent asserted against Amazon was abstract and invalid.

In a non-precedential disposition, the U.S. Court of Appeals for the Federal Circuit affirmed the district court’s summary judgment for Amazon, determining that Rensselaer’s artificial intelligence-related patent was invalid as abstract. The Federal Circuit determined that the claims of the ’798 patent are directed to ineligible subject matter under 35 U.S.C. § 101 (Rensselaer Polytechnic Institute v. Amazon.com, Inc., No. 24-1725 (Fed. Cir. Feb. 24, 2026)).

Background. Rensselaer Polytechnic Institute and CF Dynamic Advances LLC (collectively, Rensselaer) sued Amazon.com, Inc. (Amazon) in the Northern District of New York for infringement of United States Patent No. 7,177,798 (’798 patent). The ’798 patent entitled “Natural Language Interface Using Constrained Intermediate Dictionary of Results” discloses a method for processing a natural language input provided by a user. Amazon countersued for a determination that the ’798 patent was directed to patent ineligible subject matter. The district court concluded that the ’798 patent was directed towards an abstract idea, failing to exhibit an inventive concept that significantly exceeded the abstract idea. The district court granted summary judgment for Amazon, determining that the ’798 patent claimed ineligible subject matter under the Supreme Court’s decision in Alice Corp. v. CLS Bank Int’l, 573 U.S. 208 (2014).

Alice step one. The Federal Circuit noted that in evaluating a software patent, the Alice inquiry often examines whether the claims focus on a specific technological improvement to computer capabilities or merely invoke computers as a tool that implements an abstract idea. On appeal, Rensselaer argued that the claimed improvement over the prior art is the novel application of case-based reasoning to the context of natural language processing and that this improvement renders the claims non-abstract at Alice step one.

Citing Recentive Analytics, Inc. v. Fox Corp., 134 F.4th 1205 (Fed. Cir. 2025), the Federal Circuit noted that generic use of AI without other parameters, such as improving the mathematical algorithm or making machine learning better, is abstract. Additionally, a claim that merely restricts an abstract idea to a particular field or environment is still directed to the abstract idea.

Rensselaer argued that at step one, the claims of the ’798 patent are different in one respect from the claims considered in Recentive and involve something more than the mere use of AI in natural language processing. However, the Federal Circuit found the use of case information in the claimed database simply involves the use of AI as applied to a new environment and cannot render the claims non abstract under Recentive. Nor does the database otherwise involve a non-abstract concept. Thus, adding new content to a database is insufficient to render claims directed to a database non-abstract.

The Federal Circuit also found that the intrinsic record does not support Rensselaer’s argument that the metadata database is otherwise unconventional. There is no suggestion in the specification that these other elements are not conventional or that the combination of the other elements is not conventional. As to extrinsic evidence, Amazon’s expert testified that “the metadata database was admittedly well-understood, routine, and conventional at the time of the patent’s filing.” Further, the Federal Circuit noted that once the district court determined that Amazon satisfied its burden it was incumbent upon Rensselaer, as the nonmoving party, to produce some evidence refuting Amazon’s claim. However, contrary to Rensselaer’s position on appeal that the claimed database is unconventional, Rensselaer did not present any evidence to prove there was a dispute of fact related to this theory that precluded a grant of summary judgment in Amazon’s favor. Rensselaer’s expert never asserted that, apart from the case-based component of the database, the claimed database was unconventional. This was insufficient to raise a genuine dispute of fact as to whether the remainder of the database was conventional.

Alice step two. At step two, Rensselaer argued that “it is undisputed that case-based reasoning did not exist anywhere within the NLP field before the ’798 Patent,” and that the “ordered combination did not exist prior to the invention memorialized in the ’798 patent.” However, these arguments relate to novelty, and the Federal Circuit held in Recentive that at step two, the use of AI in a novel field is not an inventive concept. The Federal Circuit found that a conventional application of case-based reasoning, even to a novel environment, is abstract. Therefore, the application of case-based reasoning to natural language processing does not provide an inventive concept sufficient to render the claims patent-eligible at step two of Alice.

Accordingly, the Federal Circuit concluded that the claims of the ’798 patent are directed to ineligible subject matter.

The Case is No. 24-1725.

Judge: Dyk, T.

Attorneys: Li Zhu (Robins Kaplan LLP) for Rensselaer Polytechnic Institute. Jeremy Angus Anapol (Morgan, Lewis & Bockius LLP) for Amazon.com, Inc.

Companies: Amazon.com, Inc.

Cases: Patent FedCirNews TechnologyInternet USPTO AINews