IP Law Daily, PATENT—N.D. Cal.: Judgment on pleadings denied in network transmission dispute, (Feb 13, 2026)

By Kevin M. Finson, J.D.

Claims relating to control of packets in network transmissions were not abstract because they were directed at solving a specific technological problem occurring in a specific kind of network device.

A manufacturer of network devices failed to show that two patents asserted against it were invalid for being directed at an abstract idea, the U.S. District Court in San Jose has held. In its motion for judgment on the pleadings, the manufacturer contended that the patents were invalid because their claims fall within the “abstract ideas” exception to 35 U.S.C. § 101. However, the court found that the claim language was directed to specific technological improvements in network transmission (Universal Connectivity Technologies Inc. v. HP Inc., No. 5:24-cv-04097-NW (N.D. Cal. Feb. 9, 2026)).

Patents. Universal Connectivity Technologies, Inc. (UCT) is the owner of several patents relating to network technology, which it asserted in an infringement suit against HP, Inc. (HP). HP sought judgment on the pleadings that two of the eight asserted patents, U.S. Patents No. 7,154,905 (the ’905 patent) and 7,746,798 (the ’798 patent) were invalid for being directed at an unpatentable abstract idea. These two patents concerned specifically the use of “control packets” in network transmissions and the use of “synchronization primitives” to indicate the packet type, respectively. The court applied the two-step Alice test.

Abstract idea. With regard to both patents, HP argued that the claims recited generic, result-oriented steps for transmitting and receiving data or synchronization information. The court agreed with UCT, however, that the focus must be on the claim language and found that both patents’ claims encompassed a specific device that transmits data using particular techniques over a network to solve specific, technological problems relating to network transmission speed. The claims were directed at specific technological improvements, not to abstract ideas. For example, one claim was not directed to simply any device that transmits data packets in particular order but instead encompassed a specific device that transmits data packets over a communication link using a transmission component and with a preemption component that can preempt the transmission through a specialized process.

Because neither patent was directed to an abstract idea, the court denied the motion for judgment on the pleadings without reaching step two of the Alice test.

The Case is No. 5:24-cv-04097-NW.

Judge: Wise, N.

Attorneys: Brett E. Cooper (BC Law Group, PC) for Universal Connectivity Technologies Inc. B. Trent Webb (Shook Hardy & Bacon L.L.P.) for HP Inc.

Companies: Universal Connectivity Technologies Inc.; HP Inc.

Cases: Patent CaliforniaNews