Opinions — Monday, February 9, 2026

The Federal Circuit reversed the district court's denial of summary judgment of invalidity and held all asserted claims of U.S. Patent Nos. 8,478,245, 8,989,715, and 8,103,865—owned by GoTV Streaming, LLC and asserted against Netflix, Inc.—patent-ineligible under 35 U.S.C. § 101. The court reversed the district court's step-one determination that the claims were not directed to an abstract idea and concluded that the claims failed at step two of the Alice framework because they lacked an inventive concept sufficient to transform the abstract idea into patent-eligible subject matter. The court also reversed the district court's indefiniteness holding as to the '865 patent claims, adopting GoTV's construction of "discrete low level rendering command," but that reversal did not save the claims from ineligibility. Because the ineligibility determination required entry of judgment for Netflix, the court expressly vacated—without definitively resolving—the district court's dismissal of GoTV's induced infringement claims and its admission of certain Netflix damages evidence, noting that GoTV had raised substantial arguments on both points.

The decision underscores the Federal Circuit's willingness to resolve § 101 issues on appeal even when the district court did not reach step two of Alice, provided the parties brief both steps and no genuine factual disputes require remand. The court emphasized that patent eligibility turns on "the language of the [c]laims themselves," and that unclaimed details in the specification cannot supply the inventive concept necessary to save claims directed to abstract ideas. GoTV's failure to advance separate eligibility arguments for different claims or patents proved fatal: by relying solely on representative claim 1 of the '865 patent, GoTV effectively conceded that all asserted claims stood or fell together. The court's express vacatur of the no-inducement and evidentiary rulings, despite the case-dispositive ineligibility holding, signals concern about leaving potentially erroneous rulings intact where substantial arguments support reversal.

The Federal Circuit affirmed-in-part, vacated-in-part, and remanded the district court's final judgment of non-infringement in favor of Abiomed concerning six Maquet patents directed to intravascular blood pump systems. The appeal centered on the district court's construction of three claim limitations—"an elongate lumen associated with the cannula," "purge fluid," and "guide mechanism"—and whether summary judgment of non-infringement was properly granted for claims 16 and 17 of the '100 patent.

The court found prosecution disclaimer did not apply to narrow the "elongate lumen" limitation, holding that Maquet's statements in related inter partes review proceedings distinguishing prior art were insufficiently clear and unmistakable to constitute "words or expressions of manifest exclusion or restriction." The court rejected the district court's reliance on IPR statements to import a structural requirement that the lumen be "formed along the side of" the cannula, finding that a skilled artisan could reasonably read Maquet's statements as merely refuting the patentee's characterizations of prior art rather than disclaiming claim scope. Similarly, the court held that neither the claim language nor the specification—which expressly disclosed purge fluid flowing through ball bearing assemblies and into the bloodstream—supported importing a negative limitation precluding such flow.