Opinions — Tuesday, April 7, 2026

The Federal Circuit affirmed the Patent Trial and Appeal Board's determination that claims of Manufacturing Resources International's patents covering electronic display cooling systems were unpatentable as obvious. MRI challenged the Board's construction of "heat exchanger" and its treatment of objective evidence of nonobviousness, arguing that the term required "alternating, enclosed channels or tubes of fluid" rather than the Board's broader reading that such features were optional.

The court applied Phillips v. AWH Corp. claim construction principles, focusing on intrinsic evidence to determine that nothing in the claim language, specification, or prosecution history imposed MRI's narrower structural limitations. Although MRI argued the specification "repeatedly, consistently, and exclusively" described heat exchangers with enclosed paths, the court found the specification expressly contemplated "many types of heat exchangers" and used permissive language ("may" have particular designs) rather than mandatory limitations. The court emphasized that disclosing a single embodiment or using consistent terminology is insufficient absent a clear intent to redefine a term, and MRI's reliance on the sequence of provisional applications and their differing terminology did not establish the claimed distinction between finned devices and heat exchangers.

In IronSource Ltd. v. Digital Turbine, Inc., the Federal Circuit dismissed IronSource's appeal from a Patent Trial and Appeal Board final written decision granting Digital Turbine's revised motion to amend claims in a post-grant review for lack of Article III standing. The court held that IronSource failed to establish an injury in fact because its declarant did not link the allegedly infringing features of its discontinued product to the specific substitute claims at issue—which contained two narrowing limitations added after the alleged infringement threats—and thus failed to demonstrate concrete plans for future activity creating a substantial risk of infringement under those claims. Costs were awarded to Digital Turbine.

The Federal Circuit affirmed the Patent Trial and Appeal Board's rejection of claim 14 of Brian McFadden's patent application directed to a system for operating an information exchange. The claim recited an apparatus for determining an "exchange value" by generating a second distribution of information items from a first distribution and a specific point, then computing a distribution difference between them using means-plus-function limitations. The Board upheld the examiner's rejections under both § 101 (patent ineligibility) and § 102(a)(1) (anticipation), but the court reached only the § 101 ground.

The court's analysis demonstrates how means-plus-function claiming under § 112(f) intersects with Alice step one when the corresponding structure disclosed in the specification consists only of generic computing elements or high-level algorithmic instructions. The court held that even mathematical formulas for calculating distribution differences—which McFadden argued supplied concrete algorithmic structure—constituted abstract ideas involving data manipulation at a high level of generality, no different from generic software components for § 101 purposes. The court further applied harmless error review to reject McFadden's argument that the Board misidentified the structures associated with the means-plus-function limitations, finding that the correctly identified algorithmic structures would fare no better under Alice.

The Federal Circuit affirmed in part and reversed in part the District of Delaware's judgment following a bench trial in this patent infringement action brought by GOTV Streaming, LLC against Netflix, Inc. concerning U.S. Patents Nos. 8,024,762 and 8,103,865, which relate to streaming video technology. The court affirmed the district court's finding of no direct infringement but reversed its alternative finding of no induced infringement under 35 U.S.C. § 271(b). The central holding addresses the proper framework for evaluating induced infringement where the alleged direct infringement occurs abroad: the court held that the district court erred by requiring GOTV to prove that Netflix itself knew its customers would directly infringe, when the correct standard requires only that Netflix knew its actions would induce infringing acts and that those acts in fact occurred. The court further held that the district court's factual findings, properly construed, supported a conclusion that Netflix possessed the requisite knowledge and intent to induce infringement by its U.S.-based subscribers who streamed content using the claimed methods.

The decision clarifies the knowledge requirement for induced infringement in cases involving multinational streaming services and customer-based method claims. By distinguishing between the mental state required for inducement and the separate factual question of whether direct infringement occurred, the court reinforces that a defendant need not have specific knowledge of each customer's infringing activity, but rather must know that its actions would lead to such activity generally and that infringing acts in fact took place. This framework has immediate implications for software and service platforms that operate across borders, as it lowers the proof burden for patentees seeking to establish inducement liability where direct infringement by end users is difficult to track individually. The reversal on inducement while affirming no direct infringement also signals the viability of inducement theories even where a patentee cannot establish that the defendant itself performed all claim steps, a distinction particularly salient for method claims in the digital services context.