The Federal Circuit has issued a nonprecedential decision in Rensselaer Polytechnic Institute, CF Dynamic Advances LLC v. Amazon.com, Inc., relating to U.S. Patent No. 7,177,798 (the “798 patent”) to Rensselaer Polytechnic Institute and CF Dynamic Advances LLC (together “Rensselaer”). The court held that the ‘798 patent is invalid for being directed to ineligible subject matter. In particular, the court followed recent precedent that applying known artificial intelligence technology to a new field is not eligible for patent protection.
The ‘798 patent discloses a method for processing a natural language input provided by a user. It is directed to the application of case-based reasoning to a metadata database within natural language processing. Independent claim 1, which is representative of most of the claims, is shown below:
A method for processing a natural language input provided by a user, the method comprising:
- providing a natural language query input by the user;
- performing, based on the input, without augmentation, a search of one or more language-based databases including at least one metadata database comprising at least one of a group of information types comprising:
- case information
- keywords
- information models; and
- database values;
- providing, through a user interface, a result of the search to the user;
- identifying, for the one or more language-based databases, a finite number of database objects; and
- determining a plurality of combinations of the finite number of database objects.
The court analyzed the patent eligibility of the ‘798 patent under the two-part Alice test. Under step one, the court held that the claims are abstract, finding they largely recite the use of generic technology using standard methods. The court relied on Recentive Analytics, Inc. v. Fox Corp., 134 F.4th 1205, 1211 (Fed. Cir. 2025) for the proposition that generic use of AI without other parameters, such as improving the mathematical algorithm or making machine learning better is abstract. In particular, the Recentive court held that a claim that was directed towards applying machine learning to a new field of use was directed to an abstract idea because the only thing the claims disclose about using machine learning is that it is used in a new environment.
Rensselaer argued that the claims were not abstract because they recite a metadata database, comprising of at least one group of information types including: case information; keywords; information models; and database values. Rensselaer argued that these features represent an unconventional technological improvement that are more than the mere use of AI in natural language processing and render the claims non-abstract. However, the court held that the use of case information in the claimed database simply involves the use of AI as applied to a new environment and cannot render the claims non-abstract. Importantly, the court held that adding new content to a database is insufficient to render claims directed to a database non-abstract. The court also found that there was no suggestion in the specification that the metadata database or any other elements are not conventional. The court relied on expert testimony from the defendant, unrebutted by Rensselaer, that metadata databases are well-understood, routine and conventional at the time of the patent’s filing.
The court then went on to analyze the ‘798 patent under step two of the Alice test. Here the court held, following Recentive, that the use of AI in a novel field is not an inventive concept. In particular, a conventional application of case-based reasoning, even to a novel environment, is abstract. Therefore, the court held that the application of case-based reasoning to natural language processing does not provide an inventive concept to render the claims patent eligible at step two of Alice.
This decision reinforces a couple things to consider when drafting patent applications related to AI to ensure patent eligibility:
- Limit the use of functional language in the claims, and recite details regarding technical improvements (e.g., improvements to a machine learning algorithm).
- Include details in the specification regarding the technical improvements over instead of? conventional techniques.
If you have any questions about this case, or patent drafting strategy, contact a Dinsmore intellectual property attorney.