Federal Circuit Summary for Week Ending February 27, 2026
NimbeLink Corp. v. Digi International Inc., No. 2024-2292; non-precedential; U.S. Patent Nos. 9,497,750 and 9,838,066; February 23, 2026
Key point(s):
- Preamble language describing a claimed invention as “space-efficient” was not limiting where the claim body recited a complete device and the preamble merely described a benefit of the claimed design.
- Claims cannot be held indefinite under §112(b) based on non-limiting preamble language.
Rensselaer Polytechnic Institute v. Amazon.com, Inc., Nos. 2024-1725, 2024-1739; non-precedential; U.S. Patent No. 7,177,798; February 24, 2026
Key point(s):
- Claims that apply artificial intelligence or case-based reasoning to a new field of use, without improving computer functionality or algorithms, are directed to an abstract idea under Alice.
- Adding conventional database structures or new categories of information does not supply an inventive concept sufficient to render abstract claims patent-eligible.
Tesla, Inc. v. Charge Fusion Technologies, LLC, No. 2024-1584; non-precedential; U.S. Patent No. 10,998,753; February 25, 2026
Key point(s):
- Claim language requiring a processor to execute instructions that “result in” charging requires computer-controlled charging, not merely user-initiated charging that follows a computed schedule.
- Prior art that relies on manual user actions to start or stop charging does not disclose limitations requiring automated control by executed computer instructions.
Oasis Tooling, Inc. v. Siemens Industry Software Inc., Nos. 2024-2085, 2024-2086; non-precedential; U.S. Patent Nos. 9,803,256, 10,378,074, and 10,378,075; February 26, 2026
Key point(s):
- Claims directed to analyzing and comparing data to identify similarities and differences, even in complex technological contexts, are abstract where they automate mental processes using generic computer components.
- Reciting functional software modules (e.g., parsers, normalizers, comparers) without specific implementation details does not supply an inventive concept under Alice step two.
Global Tubing LLC v. Tenaris Coiled Tubes LLC, Nos. 2023-1882, 2023-1883; non-precedential; U.S. Patent Nos. 9,497,750 and 9,838,066; February 23, 2026
Key point(s):
- Summary judgment on inequitable conduct is improper where intent to deceive and materiality turn on disputed facts and competing reasonable inferences, particularly where witness credibility is central.
- Summary judgment on a Walker Process fraud claim is improper where genuine disputes exist regarding fraudulent procurement, relevant market definition, and whether the patent holder posed a dangerous probability of monopolization.


