On May 11, the U.S. Court of Appeals for the Federal Circuit issued a precedential decision in Free Stream Media Corp. v. Alphonso Inc. in which the appellate court reversed-in-part a ruling from the Northern District of California that had denied Alphonso’s motion to dismiss the case. In overturning the district court, the Federal Circuit panel found that patent claims covering a system of presenting targeted advertising to mobile phone users based on data gathered from the user’s television were directed to an unpatentable abstract idea under 35 U.S.C. § 101.

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