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Court Of Appeals For The Federal Circuit Invalidates In-Store Product Locator Patents As Abstract Under § 101
02/18/2026On February 6, 2026, the Court of Appeals for the Federal Circuit affirmed a decision by the United States District Court for the Western District of Wisconsin, finding six patents owned by plaintiff invalid for claiming ineligible subject matter under 35 U.S.C. § 101. Innovaport LLC v. Target Corp., No. 2024-1545 (C.A.F.C. Feb. 6, 2026). The Court held that all 55 asserted claims, relating to systems for providing in-store product-location information, were directed to abstract ideas and lacked an inventive concept.
Applying step one of the Alice/Mayo Section 101 framework, the Court explained that a “telltale sign of abstraction is when claimed functions are mental processes that can be performed in the human mind or using a pencil and paper.” The Court analogized the claimed invention to a store clerk receiving a question from a customer regarding a product location, using a catalog to determine where the product is, telling the customer where the product is, and giving that customer a suggestion of another product location based on past inquiries from the customer. The Court specifically rejected plaintiff’s argument that the claims recite a “specific technique” for improving computer functionality, holding that “improving a user’s experience while using a computer application is not, without more, sufficient to render the claims directed to an improvement in computer functionality.” The claimed linking of products and providing suggestions based on user preferences were characterized as “longstanding methods of human activity, not new technological innovations.”
At the second step of the Alice/Mayo Section 101 framework, the Court further found no “inventive concept” sufficient to “transform the nature of the claim” into a patent-eligible application. Plaintiff argued that each patent contained an inventive concept in “the combination of ‘linking’ two products together in a cross-referential manner, giving a ‘suggestion’ to a customer for another product, when the customer searches for one product, and using a ‘mobile device.’” The Court rejected this argument, identifying the proposed concepts as “abstract ideas” that “cannot supply the inventive concept that renders the invention significantly more than that ineligible concept.” The “mobile device” was deemed merely a “generic computer” component that, under Alice, “cannot transform a patent-ineligible abstract idea into a patent-eligible invention.” The Court concluded that the claims recited “routine business steps, implemented on a computer, rather than ‘fundamentally chang[ing] or improv[ing] how a computer functions’.”
