IP Law Daily, PATENT—N.D. Cal.: Text-to-video company’s patent infringement lawsuit against OpenAI dismissed in its entirety, (May 13, 2026)

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

Asserted patents merely described converting text into animated video using conventional computer components and, thus, were ineligible for protection under 35 U.S.C. § 101.

A licensing entity’s patent infringement suit against OpenAI was dismissed in its entirety, as the Northern District of California held that all asserted claims were directed to abstract ideas and lacked any inventive concept under 35 U.S.C. § 101. The court granted OpenAI’s motion to dismiss without leave to amend, concluding that the asserted patents merely described the functional result of converting text into animated video using conventional computer components without disclosing any specific technological implementation (MITII, Inc. v. OpenAI OpCo, LLC, No. 5:26-cv-00191-NW (N.D. Cal. May 8, 2026)).

Background. The plaintiff, MITII, Inc., is a patent-holding company that owns a portfolio of patents relating to communication technologies, particularly text-to-video systems. The defendant, OpenAI, is a leading artificial intelligence company that develops advanced machine learning models and generative AI systems.

The dispute involved U.S. Patent Nos. 9,397,972 (the ’972 patent), 9,667,574 (the ’574 patent), 10,616,157 (the ’157 patent), and 11,005,796 (the ’796 patent). These patents, all sharing a common specification, relate to “text-to-video” technology that allows users to compose an electronic message, select an animation character, and convert the message into a video of the character speaking the text using synthesized or recorded voice.

MITII filed this lawsuit alleging that OpenAI’s text-to-video model, Sora, infringed the asserted patents. OpenAI moved to dismiss under Rule 12(b)(6), arguing that the patents were invalid under § 101 because they claimed abstract ideas implemented using generic computing components. The case was transferred from the Central District of California to the Northern District before the motion was decided.

Representative claim and abstraction analysis. The court first addressed whether a single claim could be treated as representative of all asserted claims. Finding that the MITII failed to meaningfully distinguish the claims, the court treated claim 1 of the ’972 patent as representative. Relying on Berkheimer v HP Inc., 881 F.3d 1360 (Fed. Cir. 2018), the court noted that representative treatment is appropriate where claims are substantially similar and linked to the same alleged inventive concept.

Applying the first step of the framework established in Alice Corp. Pty. v. CLS Bank Int’l, 573 U.S. 208 (2014), the court examined whether the claims were directed to an abstract idea. It found that the claims were directed to the concept of composing a message, selecting a character, converting the message into speech, generating corresponding animation, and displaying the result. This, the court held, amounted to the abstract idea of using computers to create and transmit animated messages.

The court emphasized that the claims were framed at a high level of generality and failed to specify how key steps, such as converting text into speech or generating animation, were technologically achieved. Citing Affinity Labs of Tex., LLC v. Amazon.com Inc., 838 F.3d 1266 (Fed. Cir. 2016), the court reiterated that claims lacking “limiting detail that confines the claim to a particular solution to an identified problem” are indicative of abstraction.

The court rejected MITII’s argument that the claims improved traditional messaging systems by transforming text into video. It held that the claims merely recited a desired result, creating an animated message, without disclosing a specific method for achieving that result.

Further, MITII relied on McRO, Inc. v. Bandai Namco Games Am. Inc., 837 F.3d 1299 (Fed. Cir. 2016), arguing that its claims eliminated the need for human animators and thus represented a technological improvement. The court rejected this argument, distinguishing McRO on the ground that the claims in that case were directed to specific rules governing animation. By contrast, the asserted claims here did not disclose any such rules or technical mechanisms. Instead, they broadly recited functional steps such as “converting” and “generating” without explaining how those operations were performed. The court concluded that the claims were result-oriented and therefore abstract.

No inventive concept. Proceeding to the second step of the Alice analysis, the court considered whether the claims contained an inventive concept sufficient to transform the abstract idea into patent-eligible subject matter. It concluded that they did not.

Citing Bascom Glob. Internet Servs., Inc. v. AT&T Mobility LLC, 827 F.3d 1341 (Fed. Cir. 2016), the court explained that an inventive concept requires more than the application of an abstract idea using well-understood, routine, and conventional components. The asserted claims relied on generic elements, such as servers, processing units, and electronic devices, to perform routine functions, such as transmitting, receiving, and displaying data.

The court also rejected MITII’s contention that the use of well-known animation characters constituted an inventive concept. It found that this feature was not reflected in any meaningful technical limitation in the claims and did not alter the conventional nature of the claimed steps.

Further, the court held that the licensing entity’s reliance on DDR Holdings, LLC v. Hotels.com, L.P., 773 F.3d 1245 (Fed. Cir. 2014), was misplaced. Unlike the claims in DDR Holdings, which addressed a specific problem in internet architecture, the asserted claims here did not modify or improve the functioning of computer systems. Instead, they used computers as tools to implement an abstract idea.

Futility of amendment. Having found the claims ineligible, the court denied leave to amend. It noted that any amendments would be futile because the defects arose from the patent claims themselves rather than the manner in which they were pleaded.

The Case is No. 5:26-cv-00191-NW.

Judge: Wise, N.

Attorneys: Michael Mansour Ahmadshahi (Ahmadshahi Law Offices) for MITII, Inc. Elizabeth L. Brann (Paul Hastings, LLP) for OpenAI OpCo, LLC.

Companies: MITII, Inc.; OpenAI OpCo, LLC

Cases: Patent CaliforniaNews AINews