In BPROTOCOL Foundation v. Universal Navigation,
Judge John G. Koeltl of the U.S. District Court for the Southern
District of New York dismissed patent infringement claims against
Uniswap, finding that the asserted cryptocurrency exchange patents
claim ineligible subject matter under Section 101. The message from
the court is one we've heard before: Implementing an abstract
idea on the blockchain is still just implementing an abstract
idea.
The Patents at Issue
The plaintiffs asserted two patents: U.S. Patent No. 11,107,049
(the '049 Patent) and U.S. Patent No. 11,574,291 (the '291
Patent). Both relate "to the field of exchange and evaluation
of virtual currency," or cryptocurrency. According to the
plaintiffs, they invented a "self-executing smart token system
for the blockchain that uses smart contracts to exchange one crypto
asset for another while enabling continuous liquidity, instant
conversions, and automated price discovery without the need for
