Rensselaer Polytechnic Institute, Cf Dynamic Advances LLC v. Amazon.com, Inc.

NOTE: This disposition is nonprecedential.
United States Court of Appeals
for the Federal Circuit
______________________
RENSSELAER POLYTECHNIC INSTITUTE, CF
DYNAMIC ADVANCES LLC,
Plaintiffs-Appellants
v.
AMAZON.COM, INC.,
Defendant-Appellee
______________________
2024-1725, 2024-1739
______________________
Appeals from the United States District Court for the
Northern District of New York in Nos. 1:18-cv-00549-BKS-
TWD, 1:23-cv-00227-BKS-TWD, Judge Brenda K. Sannes.
______________________
Decided: February 24, 2026
______________________
LI ZHU , Robins Kaplan LLP, Redwood City, CA, argued
for plaintiffs-appellants. Also represented by ANNIE
H UANG , New York, NY; BENJAMEN L INDEN , CYRUS A LCORN
M ORTON , NAVIN RAMALINGAM, Minneapolis, MN.
JEREMY ANGUS ANAPOL, Morgan, Lewis & Bockius
LLP, Costa Mesa, CA, argued for defendant-appellee. Also
represented by COLIN B. H EIDEMAN , Seattle, WA; G ABRIEL
K. BELL, M ATTHEW J. M OORE, Latham & Watkins LLP,
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RENSSELAER POLYTECHNIC INSTITUTE v. AMAZON. COM , INC. 2
Washington, DC; JEFFREY H. D EAN , Amazon.com, Inc., Se-
attle, WA; JOSEPH R. RE, Knobbe, Martens, Olson & Bear,
LLP, Irvine, CA.
______________________
Before D YK , SCHALL, and STARK , Circuit Judges.
D YK , Circuit Judge.
Rensselaer Polytechnic Institute and CF Dynamic Ad-
vances LLC (together, “Rensselaer”) brought suit against
Amazon.com, Inc. (“Amazon”) in the Northern District of
New York for infringement of United States Patent
No. 7,177,798 (the “’798 patent”). Amazon countersued for
a determination that the ’798 patent was directed to patent
ineligible subject matter. The district court granted sum-
mary judgment for Amazon, determining that the ’798 pa-
tent claimed ineligible subject matter under the Supreme
Court’s decision in Alice Corp. v. CLS Bank Int’l, 573 U.S.
208 (2014). We affirm.
BACKGROUND
The ’798 patent discloses a “method for processing a
natural language input provided by a user.” ’798 patent,
abstract. As Rensselaer argues, the ’798 patent is “directed
to the novel application of case-based reasoning to a
metadata database within [natural language processing].”
Appellants’ Br. 4. Rensselaer argues that case-based rea-
soning is “an established problem-solving technique for
computers,” id. at 7, and, when applied to the field of nat-
ural language processing, it uses “case information to learn
from metadata associated with past utterances” to resolve
the natural ambiguities existing in human language, such
as when one word carries multiple meanings, id. at 10. In
doing this, the claimed method can process an input of nat-
ural human language without needing to first augment the
input by translating it into a more easily readable syntax.
See id. at 5–6. In short, case-based reasoning is, in the con-
text of this patent, a type of machine learning or artificial
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RENSSELAER POLYTECHNIC INSTITUTE v. AMAZON. COM , INC. 3
intelligence (“AI”). See Appellants’ Br. 43 (“Case-based
reasoning is itself a specific form of computerized reason-
ing rooted in artificial intelligence . . . .”).
Before the district court, Rensselaer conceded that in-
dependent claim 1 of the ’798 patent is representative of
most1 of the claims and recites:
1. A method for processing a natural language in-
put provided by a user, the method comprising:
providing a natural language query input by
the user;
performing, based on the input, without aug-
mentation, 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
1 Before the district court, Rensselaer argued that
claims 2, 5, and 6 are not represented by claim 1. On ap-
peal, Rensselaer does not argue in its opening brief that
these claims require distinct analysis, and we accordingly
do not separately address them.
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RENSSELAER POLYTECHNIC INSTITUTE v. AMAZON. COM , INC. 4
determining a plurality of combinations of the
finite number of database objects.
’798 patent, claim 1.
Before the district court, the parties cross-moved for
summary judgment. The district court concluded that,
based on the patent’s intrinsic record, the claims were in-
eligible as a matter of law and granted Amazon’s motion.
Rensselaer appeals. We have jurisdiction under 28 U.S.C.
§ 1295(a)(1).
D ISCUSSION
“Whoever invents or discovers any new and useful pro-
cess, machine, manufacture, or composition of matter, or
any new and useful improvement thereof, may obtain a pa-
tent therefor . . . .” 35 U.S.C. § 101. However, the Su-
preme Court has concluded the statute should be construed
to exclude certain subject-matter from patent eligibility,
namely “[l]aws of nature, natural phenomena, and abstract
ideas.” Alice, 573 U.S. at 216; Mayo Collab. Servs. v. Pro-
metheus Lab’ys, Inc., 566 U.S. 66, 71 (2012). To determine
whether a patent improperly claims an abstract idea, we
apply the two-step analysis articulated in Alice. Alice,
573 U.S. at 217; Recentive Analytics, Inc. v. Fox Corp.,
134 F.4th 1205, 1211 (Fed. Cir. 2025), cert. denied — S. Ct.
—, No. 25-505, 2025 WL 3507020. At step one, “we deter-
mine whether the claims at issue are directed to one of
those patent-ineligible concepts.” Alice, 573 U.S. at 217.
Then, if we find they are so directed, we assess the “ele-
ments of each claim both individually and ‘as an ordered
combination’” to determine whether they contain an “in-
ventive concept” that is sufficient to transform the claimed
invention into something more than the ineligible subject
matter. Id. at 217–18 (quoting Mayo, 566 U.S. at 79).
In evaluating a software patent, the Alice inquiry often
examines whether the claims focus on a specific technolog-
ical improvement to computer capabilities or merely invoke
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RENSSELAER POLYTECHNIC INSTITUTE v. AMAZON. COM , INC. 5
computers as a tool that implements an abstract idea. Re-
centive, 134 F.4th at 1212 (citing Koninklijke KPN N.V.
v. Gemalto M2M GmbH, 942 F.3d 1143, 1149 (Fed. Cir.
2019)). This inquiry “often turns to the question of what
the patent asserts as the claimed advance over the prior
art.” GoTV Streaming, LLC v. Netflix, Inc., —F.4th—,
No. 2024-1669, 2026 WL 346200, at *7 (Fed. Cir. Feb. 9,
2026) (quoting Broadband iTV, Inc. v. Amazon.com, Inc.,
113 F.4th 1359, 1367 (Fed. Cir. 2024)). We have consist-
ently concluded that claims that use “functional, result-fo-
cused language” or merely “encompass ordinary computers
and networks to perform their ordinary functions in carry-
ing out an abstract idea, even when narrowed to a particu-
lar use or environment,” do not provide an inventive
concept capable of rendering the claims patent eligible.
GoTV, 2026 WL 346200, at *11 (collecting cases). Instead,
the claims must “require a specific implementation to im-
prove how those functions are carried out.” Id.
The district court determined that the claims were di-
rected to an abstract idea at step one and that the claims
do not contain an inventive concept capable of rendering
the claims eligible at step two. We review the district
court’s grant of summary judgment de novo. Focus Prods.
Grp. Int’l, LLC v. Kartri Sales Co., 156 F.4th 1259, 1271
(Fed. Cir. 2025) (applying Second Circuit law). Amazon is
only entitled to summary judgment if, resolving all mate-
rial factual disputes in favor of Rensselaer, Amazon is en-
titled to judgment as a matter of law. See id. (citing Fed.
R. Civ. P. 56(a)).
I
We conclude that at step one, the claims are abstract.
Here, the claims largely recite the use of generic technology
using standard methods. See, e.g., ’798 patent col. 9 ll. 18–
20 (noting the claimed invention uses a “general purpose
computer system”); id. col. 9 ll. 58–60 (“[T]he invention is
not limited to a particular computer system platform,
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RENSSELAER POLYTECHNIC INSTITUTE v. AMAZON. COM , INC. 6
processor, operating system, or network.”); id. col. 9 ll. 60–
64 (noting that “other appropriate computer systems could
also be used”). On appeal, Rensselaer nonetheless argues
that the claimed improvement over the prior art is the
novel application of case-based reasoning to the context of
natural language processing and that this improvement
renders the claims non-abstract at Alice step one. See, e.g.,
Appellants’ Br. 59 (“[T]he [’798] [p]atent . . . provid[ed] a
novel [natural language processing] system that imple-
mented, for the first time, case-based reasoning . . . .”). We
disagree.
Generic use of AI without other parameters, such as
“improving the mathematical algorithm or making ma-
chine learning better,” is abstract. Recentive, 134 F.4th
at 1213. A claim that merely restricts an abstract idea to
a particular field or environment is still directed to the ab-
stract idea. See Recentive, 134 F.4th at 1213; GoTV,
2026 WL 346200, at *8; Intell. Ventures I LLC v. Capital
One Bank (USA), 792 F.3d 1363, 1366 (Fed. Cir. 2015). In
Recentive, we determined 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 the use of machine learning is that
machine learning is used in a new environment.” Recen-
tive, 134 F.4th at 1213. Rensselaer concedes that, under
Recentive, claims that require nothing more than applica-
tion of artificial intelligence to a new environment are di-
rected to an abstract idea.
It follows under Recentive that in the context of soft-
ware patents the application of a well-established idea
(case-based reasoning or AI) to a novel environment (natu-
ral language processing) is abstract at step one of the Alice
analysis.
II
Rensselaer argues that at step one, the claims of the
’798 patent are different in one respect from the claims we
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RENSSELAER POLYTECHNIC INSTITUTE v. AMAZON. COM , INC. 7
considered in Recentive and involve something more than
the mere use of AI in natural language processing. The
independent claims here recite a “metadata database, com-
prising at least one of a group of information types compris-
ing: case information; keywords; information models; and
database values.” ’798 patent, claims 1, 9, which Rensse-
laer argues on appeal represents an unconventional tech-
nological improvement that renders the claims, as a whole,
non-abstract.
The use of case information in the claimed database
simply involves the use of AI as applied to a new environ-
ment and cannot render the claims non abstract under Re-
centive. Nor does the database otherwise involve a non-
abstract concept. Our cases suggest that adding new con-
tent to a database is insufficient to render claims directed
to a database non-abstract. See BSG Tech LLC
v. Buyseasons, Inc., 899 F.3d 1281, 1288 (Fed. Cir. 2018)
(“[A]n improvement to the information stored by a data-
base is not equivalent to an improvement in the database’s
functionality.”); Intell. Ventures I LLC v. Erie Indemnity
Co., 850 F.3d 1315, 1328 (Fed. Cir. 2017) (adding ‘tags’ to
database entries was abstract); Elec. Power Grp., LLC
v. Alstom S.A., 830 F.3d 1350, 1353 (Fed. Cir. 2016) (con-
sidering “collecting information, including when limited to
particular content” to be an “abstract idea[]”). We need not
decide the question whether adding non-conventional data
to a conventional database is non-abstract here because,
here, the remaining information types comprising the
claimed database were established to be conventional.2
2 Conventionality is often considered during the step
two analysis, which requires a determination as to whether
the claimed “improvements in the recited computer tech-
nology go beyond ‘well-understood, routine, conventional
activit[ies]’ and render the invention patent-eligible.”
BASCOM Glob. Internet Servs., Inc. v. AT&T Mobility
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RENSSELAER POLYTECHNIC INSTITUTE v. AMAZON. COM , INC. 8
The use of a data structure that is “already routine and
conventional” will not render a claim non-abstract. See
GoTV, 2026 WL 346200, at *9.
The intrinsic record does not support Rensselaer’s ar-
gument that the metadata database is otherwise uncon-
ventional. There is no suggestion in the specification that
these other elements are not conventional or that the com-
bination of the other elements is not conventional. The
specification indicates that, generally, a metadata data-
base “is well-known in the art of data and knowledge man-
agement tools,” ’798 patent, col. 16 ll. 16–18. The use of
keywords is conventional. See, e.g., id. col. 13 l. 61–col. 14
l. 1 (recognizing that conventional natural language pro-
cessing methods utilized keywords). The district court’s
construction of “information models” suggest they are
broadly and generically claimed. See J.A. 2613 (construing
“information models” to mean “webs of concepts for enter-
prise databases”). The specification’s description of “data-
base values” as “database computational operators”
likewise suggests that these, too, are generic components
of conventional databases. ’798 patent, col. 30 ll. 27–28.
As to extrinsic evidence, Amazon’s expert testified that
“the metadata database was admittedly well-understood,
routine, and conventional at the time of the patent’s filing.”
J.A. 3223. Contrary to Rensselaer’s position on appeal that
the claimed database is unconventional, Rensselaer did not
present evidence below to argue there was a dispute of fact
related to this theory that precluded a grant of summary
judgment in Amazon’s favor. Rensselaer’s expert never as-
serted that, apart from the case-based component of the
LLC, 827 F.3d 1341, 1348 (Fed. Cir. 2016) (alteration in
original) (quoting Alice, 573 U.S. at 225). We have also “re-
peatedly analyzed conventionality at step one as well.”
CareDx, Inc. v. Natera, Inc., 40 F.4th 1371, 1379 (Fed. Cir.
2022).
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database, the claimed database was unconventional. This
was insufficient to raise a genuine dispute of fact as to
whether the remainder of the database was conventional.
Once the district court determined that Amazon satisfied
its burden, and we agree that it did, it was incumbent upon
Rensselaer, as the nonmoving party, to produce some evi-
dence refuting Amazon’s claim. See Enzo Biochem v. Gen-
Probe, Inc., 424 F.3d 1276, 1284 (Fed. Cir. 2005) (“Attorney
argument is no substitute for evidence.”). Rensselaer failed
to do so.
III
The arguments that Rensselaer raises fare no better at
step two than step one. “An inventive concept . . . must be
significantly more than the abstract idea itself.” BASCOM,
827 F.3d at 1349. So too, “simply appending conventional
steps, specified at a high level of generality,” to a method
“well known in the art” and consisting of “well-understood,
routine, conventional activit[ies]” previously engaged in by
workers in the field, is not sufficient to supply the inventive
concept. Alice, 573 U.S. at 221–22, 225.
At step two, Rensselaer argues that “it is undisputed
that case-based reasoning did not exist anywhere within
the NLP field before the [’798] Patent,” Appellants’ Br. 52,
and that the “ordered combination did not exist prior to the
invention memorialized in the [’798] patent,” id. at 54.
However, these arguments speak to novelty, which is a sep-
arate inquiry, and we held in Recentive that at step two,
the use of AI in a novel field is not an inventive concept.
134 F.4th at 1214–15. A conventional application of case-
based reasoning, even to a novel environment, is abstract.
Therefore, the application of case-based reasoning to natu-
ral language processing does not provide an inventive con-
cept sufficient to render the claims patent-eligible at step
two of Alice.
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CONCLUSION
We have considered Rensselaer’s other arguments3 and
find them unpersuasive. We therefore conclude that the
claims of the ’798 patent are directed to ineligible subject
matter under § 101.
AFFIRMED
COSTS
Costs to Amazon.
3 It its opening brief, Rensselaer does not argue that
any of the dependent claims contain elements that would
change our analysis. In its reply brief, Rensselaer argues
that the “reference dictionary” claimed in claims 4, 14, and
the claims depending from those claims renders those
claims patent eligible. These belated arguments, even if
we do not consider them forfeited, are unavailing. The
term, “reference dictionary” was construed to mean a “set
of database entries or objects and their relations.”
J.A. 2613. There is no question that reference dictionaries
were “commonly understood” in the art, J.A. 345, and we
do not read the claims, as construed, to provide any struc-
tural details that suggest a different conclusion.
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