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ARTICLE · 28 APRIL 2025

Federal Circuit Refines Section 101 Eligibility As Applied To Machine Learning Patents

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On April 18, 2025, the United States Court of Appeals for the Federal Circuit ("Federal Circuit") issued a significant decision in Recentive Analytics, Inc. v. Fox Corp.

United StatesIntellectual Property
Nick Palmieri
Nick Palmieri

On April 18, 2025, the United States Court of Appeals for the Federal Circuit ("Federal Circuit") issued a significant decision in Recentive Analytics, Inc. v. Fox Corp., affirming dismissal, by the District Court of Delaware, of patent infringement claims brought by Recentive Analytics, Inc. ("Recentive") against Fox Corp. and affiliates (collectively, "Fox"). The case centered on four patents owned by Recentive—U.S. Patent Nos. 10,911,811, 10,958,957, 11,386,367, and 11,537,960—which purported to cover the use of machine learning for generating event schedules and network maps, particularly in the context of television broadcasts and live events.

The patents generally fell into two categories:

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