Rfc Lenders of Texas, LLC v. Smart Chemical Solutions, LLC

N OTE: This disposition is nonprecedential.
United States Court of Appeals
for the Federal Circuit
______________________
RFC LENDERS OF TEXAS, LLC,
Plaintiff-Appellant
v.
SMART CHEMICAL SOLUTIONS, LLC,
Defendant-Appellee
______________________
2025-1044
______________________
Appeal from the United States District Court for the
Western District of Texas in No. 6:23-cv-00832-XR, Judge
Xavier Rodriguez.
______________________
Decided: April 29, 2026
______________________
K ENNETH T. EMANUELSON, II, The Emanuelson Firm,
P.C., Dallas, TX, for plaintiff-appellant. Also represented
by S TEVEN EDWARD R OSS , Maxus Legal PLLC, Dallas, TX.
MICHAEL J. ZINNA , Kelley Drye & Warren, LLP, New
York, NY, for defendant-appellee. Also represented by
VINCENT F ERRARO.
______________________
Before D YK, P ROST , and CUNNINGHAM , Circuit Judges.
Case: 25-1044 Document: 45 Page: 1 Filed: 04/29/2026

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RFC LENDERS OF TEXAS, LLC v.
SMART CHEMICAL SOLUTIONS, LLC
2
P ROST , Circuit Judge.
RFC Lenders of Texas, LLC (“RFC”) appeals an order
of the U.S. District Court for the Western District of Texas
granting Smart Chemical Solutions, LLC’s (“Smart Chem-
ical”) motion to dismiss on the basis that the asserted pa-
tent’s claims are ineligible for patenting under 35 U.S.C.
§ 101. RFC Lenders of Tex., LLC v. Smart Chem. Sols.,
LLC, 743 F. Supp. 3d 911, 924 (W.D. Tex. 2024). For the
following reasons, we affirm.
BACKGROUND
RFC owns U.S. Patent No. 7,430,471 (“the ’471 pa-
tent”), which relates to monitoring vehicles for “unauthor-
ized usage.” ’471 patent col. 3 ll. 53–61. The ’471 patent
acknowledges that “[s]ystems are presently available to au-
tomatically provide the present location of a” vehicle. Id. at
col. 1 ll. 18–23. It offers a purported improvement by sug-
gesting that a system can determine unauthorized usage
based on an operator identification being received (or not)
within a time interval of detecting vehicle “activation or
tampering.” Id. at col. 2 ll. 31–35. It also explains that “a
presence of the vehicle is detected at a landmark,” which
can be “any geographic location.” Id. at col. 3 ll. 7–9. As an
example, the vehicle may include a monitoring system that
can detect a radio frequency identification (“RFID”) tag
contained in a landmark such as a parking stall. Id. at
col. 3 ll. 13–21. Or, from the landmark’s perspective, “a
reader at the parking stall” can detect an RFID tag on the
vehicle. Id. at col. 3 ll. 21–28. Claim 1 recites:
A method for monitoring a vehicle, comprising:
detecting movement or activation of the vehicle;
transmitting a signal indicating movement or acti-
vation of the vehicle, to a control center;
transmitting any received operator identification
information to the control center;
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RFC LENDERS OF TEXAS, LLC v.
SMART CHEMICAL SOLUTIONS, LLC
3
determining whether an operator identification
was received within a time interval of the detected
movement or activation of the vehicle;
detecting at the vehicle the presence of a landmark;
and
transmitting data identifying the landmark and/or
a location of the landmark to the control center.
Id. at claim 1. Independent claim 15 is similar to claim 1
except that it does the detecting from the opposite perspec-
tive, i.e., “detecting at a landmark the presence of the vehi-
cle,” and “transmitting data identifying the vehicle.” Id. at
claim 15 (emphasis added).
RFC sued Smart Chemical for infringing one or more
claims of the ’471 patent. Smart Chemical moved to dis-
miss the complaint under Federal Rule of Civil Procedure
12(b)(6), arguing all claims of the ’471 patent are ineligible
under § 101. The district court granted Smart Chemical’s
motion and denied RFC’s motion for leave to amend its
complaint due to futility.
RFC timely appealed. We have jurisdiction under
28 U.S.C. § 1295(a)(1).
D ISCUSSION
We review a district court’s decisions on motions to dis-
miss and motions for leave to amend under the law of the
regional circuit. Mobile Acuity Ltd. v. Blippar Ltd., 110
F.4th 1280, 1288 (Fed. Cir. 2024). The Fifth Circuit re-
views decisions on Rule 12(b)(6) motions to dismiss de
novo, see, e.g., Molzan v. Bellagreen Holdings, LLC, 112
F.4th 323, 331 (5th Cir. 2024), and when a district court
denies leave to amend due to futility, the Fifth Circuit re-
views that decision de novo as well, Martinez v. Nueces
County, 71 F.4th 385, 390–91 (5th Cir. 2023). To survive a
Rule 12(b)(6) motion, a complaint must allege enough facts
that, accepted as true, “state a claim to relief that is
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RFC LENDERS OF TEXAS, LLC v.
SMART CHEMICAL SOLUTIONS, LLC
4
plausible on its face.” Bell Atl. Corp. v. Twombly, 550
U.S. 544, 570 (2007).
I
Patent eligibility under § 101 is a question of law that
may involve underlying questions of fact. Interval Licens-
ing LLC v. AOL, Inc., 896 F.3d 1335, 1342 (Fed. Cir. 2018).
“We review the district court’s ultimate conclusion on pa-
tent eligibility de novo.” Id.
To evaluate patent eligibility under § 101, we apply the
familiar Alice two-step framework. At step one, we deter-
mine whether the claim at issue is “directed to” a patent-
ineligible concept, such as an abstract idea. See Alice
Corp. v. CLS Bank Int’l, 573 U.S. 208, 218 (2014). Under
this directed-to inquiry, “we ask what the patent asserts to
be the focus of the claimed advance over the prior art to
determine whether the claim’s character as a whole is di-
rected to ineligible subject matter.” Simio, LLC v. FlexSim
Software Prods., Inc., 983 F.3d 1353, 1359 (Fed. Cir. 2020)
(cleaned up). If the claim is directed to an abstract idea at
step one, we move to step two, “where we examine the ele-
ments of the claim to determine whether it contains an in-
ventive concept sufficient to transform the claimed
abstract idea into a patent-eligible application.” Id.
(cleaned up). If the claim contains no such inventive con-
cept at step two, it is patent ineligible.
As an initial matter, RFC contends that the district
court erred by determining claim 1 to be representative of
all claims of the ’471 patent.1 RFC argues that certain lim-
itations from the dependent claims “further specify the im-
proved method for monitoring and controlling vehicles,”
and thus claim 1 is not representative of those claims. Ap-
pellant’s Br. 40–41. RFC has forfeited that argument by
1 RFC concedes, however, that claim 1 is representa-
tive of claim 15. Appellant’s Br. 37 n.8.
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RFC LENDERS OF TEXAS, LLC v.
SMART CHEMICAL SOLUTIONS, LLC
5
failing to raise it before the district court. See In re Watts,
354 F.3d 1362, 1367–68 (Fed. Cir. 2004). And in any event,
we see no error in the district court’s treatment of claim 1
as representative because, as discussed below, the addi-
tional limitations found in the dependent claims only “tack
on generic computer components . . . or introduce conven-
tional computer activities.” See Mobile Acuity, 110 F.4th at
1291–92.
A
At Alice step one, the district court concluded that rep-
resentative claim 1 of the ’471 patent is directed to the ab-
stract idea of “detecting, transmitting, and processing data
to monitor vehicles.” RFC, 743 F. Supp. 3d at 920. RFC
argues that the district court overgeneralized the claims
and failed to consider their detailed limitations. We disa-
gree.
The district court properly characterized the claims as
being directed to the basic concept of monitoring vehicles
and lacking any “concrete or tangible form.” Id. The claims
invoke only generic computing functions (“detecting . . .;
transmitting . . .; determining . . .”) in result-oriented lan-
guage without providing specifics as to how to achieve the
claimed results. For example, the step of “detecting at the
vehicle the presence of a landmark” lacks any meaningful
detail regarding how to do so in a nonconventional way.2
2 On appeal, RFC argues that the claimed advance is
the ability to “control” monitored vehicles. Appellant’s
Br. 23. While RFC argued before the district court that
there was an inventive concept in the claims because they
describe transmitting to the control center information re-
garding whether a driver of a vehicle was authorized, there
was no argument that the claims cover control of the vehi-
cle based on that information. Further, the claims on their
face do not cover any such activity.
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RFC LENDERS OF TEXAS, LLC v.
SMART CHEMICAL SOLUTIONS, LLC
6
Thus, examining claim 1 as a whole, we determine that it
is not directed to any computer improvement, but rather is
directed to an abstract idea that merely invokes computers
as tools.
The dependent claims also fail to add any meaningful
specificity, and instead, “offer little more than minor vari-
ations,” as the district court properly found. RFC, 743
F. Supp. 3d at 918. For example, claims 10 and 11 recite
that “detection is performed by a[n] [RFID] transceiver,”
without any further meaningful detail. Nor does the spec-
ification provide any significant accompanying description.
See ’471 patent col. 2 ll. 7–11 (describing an RFID reader
as merely one among “any other reader capable of or ar-
ranged to receive information from the token presented by
the operator”). This is yet another example of the claims
tacking on generic computer components or introducing
conventional computer activities, and it underscores that
the claims are linked to the same ineligible concept. See
Mobile Acuity, 110 F.4th at 1290–91. We thus agree with
the district court’s conclusion that representative claim 1
is directed to the abstract idea of “detecting, transmitting,
and processing data to monitor vehicles.” RFC, 743
F. Supp. 3d at 920.
B
At Alice step two, we agree with the district court that
representative claim 1 lacks an inventive concept that
transforms the abstract idea here into a patent-eligible in-
vention. Id. at 922. Before us, RFC largely repeats its Alice
step-one argument regarding unclaimed “control” func-
tions, which is also raised for the first time on appeal and
therefore forfeited. And as to RFC’s argument that the dis-
trict court misinterpreted the specification’s admissions
that its methods can be implemented using conventional
components, we see no error in the district court’s analysis.
As the specification makes clear, the claimed steps are
themselves conventional, well-understood, and routine,
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RFC LENDERS OF TEXAS, LLC v.
SMART CHEMICAL SOLUTIONS, LLC
7
and any of the generic computer components invoked
therein would only operate according to their ordinary
functions to carry out the claimed functions. See ’471 pa-
tent col. 5 ll. 48–59.
Accordingly, we agree with the district court that the
claims of the ’471 patent fail both Alice steps and are there-
fore ineligible under § 101.
II
We next address whether the district court properly de-
nied RFC’s motion for leave to amend its complaint. RFC’s
main argument appears to be that the district court made
“an improper finding of fact” as to the Alice step-two in-
quiry. Appellant’s Br. 42. That argument fails. The dis-
trict court explained that it need not credit “conclusory
allegations” that the claimed steps were not well-known,
routine, and conventional, particularly when “the specifi-
cation acknowledges that the ’471 [p]atent’s claims could
be carried out using conventional computing components.”
RFC, 743 F. Supp. 3d at 922–24. Conclusory allegations
need not be credited as true at the motion-to-dismiss stage,
Ferrer v. Chevron Corp., 484 F.3d 776, 780 (5th Cir. 2007),
including allegations contradicted by the specification, see
Secured Mail Solutions LLC v. Universal Wilde, Inc., 873
F.3d 905, 913 (Fed. Cir. 2017). We thus see no error in the
district court’s determination.
CONCLUSION
We have considered RFC’s remaining arguments and
find them unpersuasive. For the foregoing reasons, we af-
firm.
AFFIRMED
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