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ARTICLE · 06 MAY 2025

Federal Circuit Refines Section 101 Eligibility Of Machine Learning Inventions

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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 PLAnalytics, Inc. v. Fox Corp.

United StatesIntellectual Property
Christopher J. Palermo
Christopher J. Palermo
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., Case No. 2023-2437 (Apr. 18, 2025), 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—relating to using 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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