IP Law Daily, PATENT—Fed. Cir.: Sharing of content with a unique identifier was an unpatentable abstract idea, (Feb 5, 2026)

By Kevin M. Finson, J.D.

Claims relating to systems and methods for sharing content over a network were invalid because they were directed to an abstract idea and lacked an inventive concept.

Walmart successfully showed that patent claims asserted against it were invalid for being directed to an abstract idea, the U.S. Court of Appeals for the Federal Circuit has held. The asserted patents simply implemented longstanding economic practices on generic and conventional computer components (Q Technologies, Inc. v. Walmart, Inc., No. 24-1667 (Fed. Cir. Feb. 5, 2026)).

Q Technologies, Inc. (Q Tech) was the owner of U.S. Patents Nos. 9,635,108 (the ’108 patent), 10,567,473 (the ’473 patent), and 10,594,774 (the ’774 patent), all of which shared a specification and related to methods and systems for content sharing using uniquely generated identifiers, specifically disclosing a system whereby a first client sends shared content, a unique identifier, and its location to a server, which stores the shared content. A second client may then request that content by providing the identifier and its own location. Q Tech brought suit for infringement of all three patents against Walmart, Inc. (Walmart). Walmart moved for summary judgment, stating that the asserted claims were patent ineligible due to being directed at an abstract idea. The trial court applied the two-step Alice test and found in favor of Walmart. Q Tech appealed.

Abstract idea. The court found that the trial court did not err in finding that the representative claim was directed to the abstract idea of sharing content using a unique identifier. There was nothing in the record to show a technological improvement to computer networks or file-sharing technology itself, only the exchange of information. It reflected a longstanding economic practice that was simply implemented with generic and conventional computer components.

Inventive concept. The court also found that the claim only recited well understood, routine, and conventional activities, and lacked any nonconventional implementation or improvement in computer functionality which could show an inventive concept.

The court affirmed the grant of summary judgment in favor of Walmart.

The Case is No. 24-1667.

Judge: Lourie, A.

Attorneys: Rayiner Hashem (Mololamken LLP) for Q Technologies, Inc. Gabriel K. Bell (Latham & Watkins LLP) for Walmart, Inc.

Companies: Q Technologies, Inc.; Walmart, Inc.

Cases: Patent FedCirNews