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Explore the latest in patent, trademark, and copyright cases on the Merchant & Gould LLP blog. Stay informed with expert insights on intellectual property law updates.

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Last week, the U.S. Court of Appeals for the Federal Circuit issued a non-precedential opinion in <a href="https://www.cafc.uscourts.gov/opinions-orders/24-1721.OPINION.7-23-2026_2727215.pdf">Ceiva Opco, LLC v. Amazon.com, Inc., No. 2024-1721 (July 23, 2026)</a>, re-affirming its approach to abstract claims under Alice and its progeny. The Court affirmed- and reversed-in-part a district court’s grant of summary judgment holding that Ceiva’s patents were invalid under 35 U.S.C. § 101.

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The patents shared a common specification disclosing methods and apparatuses for distributing digital pictures to a frame device.

On appeal, the Federal Circuit reversed with respect to the ’573 patent, holding that it satisfied Alice step one because the exemplary claim was directed towards “a technological solution to a technological problem” under Ollnova Techs. Ltd. v. ecobee Techs. ULC, 177 F.4th 1343, 1360–62 (Fed. Cir. 2026), and not an abstract idea. The combination of a digital picture frame and a “physically separable” user interface that allowed a user to upload images and change the settings of the digital picture frame via the user interface represented a patent eligible, technical advancement.

The Court reached the opposite conclusion for the broader claims of the ’930, ’562, and ’656 patents, affirming ineligibility under § 101. The Court determined the claims from the three patents directed to a “digital display device” were abstract ideas under Alice step one because many of the claims did not even mention a “user interface,” and some included “software” broadly configured to achieve various functions, but in no specific way. The claims also failed under Alice step two, because the components and functions of the claims did nothing more than implement an abstract idea of “automatically accessing a remote data repository to obtain updated content without the use of a computer and without any further user input.” Unlike the ’573 patent claims, the claims of the ’930, ’562, and ’656 patents did not sufficiently explain how the claimed remote functionality was implemented and therefore claimed only the desired result of automatically accessing remote content.

The Court also rejected Ceiva’s argument that industry praise for its commercial product was evidence of patent eligibility, holding that secondary considerations of nonobviousness are irrelevant to eligibility. Further, the Court determined Ceiva did not explain how such evidence would relate to the eligibility of any claim element or combination of claim elements.

CAFC Again Addresses Patent Eligibility Under Alice and its Progeny

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