CAFC – Constellation Designs v. LG Electronics (Patent Eligibility, 2026)

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## CAFC – Constellation Designs v. LG Electronics (Patent Eligibility, 2026) A precedential Federal Circuit decision distinguishing between "results-oriented" patent claims (ineligible under § 101) and claims with "specificity and structure" (eligible), with significant implications for software and signal processing patent strategy. ### The Decision - The U.S. Court of Appeals for the Federal Circuit (CAFC) issued a **precedential** ruling in *Constellation Designs, LLC v. LG Electronics Inc.* (IPWatchdog, April 28, 2026) - The court **vacated in part and affirmed in part** the Eastern District of Texas's § 101 eligibility analysis - The CAFC found the district court **incorrectly** held the "optimization claims" eligible — characterizing them as impermissibly results-oriented - The CAFC **affirmed** that the "constellation claims" were correctly found eligible due to their specificity and structure (IPWatchdog, April 28, 2026) ### Legal Framework - **35 U.S.C. § 101** governs patent-eligible subject matter; the Alice/Mayo framework applies to abstract idea and natural phenomenon exclusions - The decision adds precedential weight to the distinction between claims that merely recite a desired outcome versus claims that specify a concrete technical implementation ### Significance for Patent Practice - Provides clearer guidance on how to draft and argue software and signal processing claims to survive § 101 challenges - "Results-oriented" claiming — specifying what a system achieves without how — remains high risk post this decision - Practitioners should audit existing portfolios for optimization claims that may now be vulnerable under this reasoning - The Eastern District of Texas ruling being partially reversed underscores that even favorable district court findings can be overturned on eligibility ### Strategic Implications - Patent prosecutors drafting claims in communications, AI, and software should emphasize structural specificity - NPEs and operating companies holding optimization-style patent portfolios face new § 101 exposure