Constellation Designs v. LG: Result-Oriented Claims

Four patents, one family, two kinds of claim, two different answers. That is what makes this the clearest teaching case in this cluster: you can see what moved a claim from one side of the line to the other without comparing two unrelated patents.

Of claim 17, the court said "we conclude that claim 17 is ineligible because it is an abstract, result-oriented claim directed to all ways of achieving a recited result." It reached that by comparison with O'Reilly v. Morse, the 1853 Supreme Court decision that upheld Morse's claims to the details of the telegraph and struck down the broad one.

What Separated the Two Sets

The court's description of the defect is worth reading slowly. "The claim itself does not recite how to achieve a constellation" optimized for that measure; instead "this important and distinguishing element of the claim is described in a result-oriented way." The breadth that follows is what the court identified as the abstract idea itself.

The patentee's best argument was that the claims did recite a concrete technique, namely using parallel decode capacity to optimize. The court's answer was that claim 17 "lacks sufficient details about the alleged" technique.

The Specification Does Not Rescue the Claim

The same idea appears twice in the opinion. "the specification may help illuminate the true focus" of a claim, but the eligibility inquiry is about the claim. A thorough description is necessary for other reasons, including enablement and written description. It is not a substitute for putting the mechanism in the claim.

That is the same lesson GoTV v. Netflix and Columbia v. Gen Digital reach from different directions, and this decision states it with an eligible counterexample sitting next to the ineligible claims.

The Opinion You Should Cite Is the August One

The panel modified and reissued this opinion on 31 August 2026 after a petition for rehearing. The reissued document carries both dates in its header and a footnote saying "This opinion has been modified and reissued following a petition for rehearing." Everything above is unchanged by the modification: we compared the two documents sentence by sentence, and the eligibility analysis and the disposition paragraph are word for word identical.

One passage was removed. In the April version, the footnote disposing of LG's damages argument gave a backup reason on the merits. The August version stops at the procedural one. What survives is the procedural holding, and it is the part worth carrying away:

The same precision explains the word vacated in the table above rather than reversed. A footnote records that "LG never crossmoved for summary judgment of patent ineligibility" and instead argued that "genuine issues of material fact preclude[d] summary judgment." The court held claim 17 ineligible and sent the claims back; it did not enter judgment against them.

What This Does Not Decide

• It states no threshold. The opinion does not say how much mechanism a claim needs, and the surviving claims were upheld because they recited specific constellations, not because they cleared a stated bar.
• It does not say whether any other claim is eligible.
• The case also addressed infringement, damages and expert testimony. Those parts are covered only in the section above.

Educational, not legal advice. Reporting what a court held is not advice on how to draft a claim, which is work for a registered practitioner.