IP / Regulatory Law Watch Innovaport LLC v. Target Corporation In Innovaport LLC v. Target Corporation, decided by the Court of Appeals Federal Circuit on February 6, 2026, the court affirmed summary judgment invalidating all 55 asserted claims from six patents related to in-store product location systems. Innovaport had sued Target for patent infringement, claiming its patents covered innovative methods for helping shoppers find products in stores using computerized systems that provide location information and product suggestions through various user interfaces, including mobile devices. An invention is patentable if it is of eligible subject matter, novel, obvious, and useful. In this case, eligible subject matter was the issue. The Alice/Mayo test is the Supreme Court’s two-step framework for determining whether a patent claim is directed to patent-ineligible subject matter under 35 U.S.C. § 101. This test serves as the primary mechanism for preventing patents on abstract ideas, laws of nature, and natural phenomena. Step one: courts determine whether the claims are “directed to” a patent-ineligible concept such as an abstract idea. Step two: courts examine whether the claim elements, individually or as an ordered combination, contain an “inventive concept” sufficient to transform the abstract idea into a patent-eligible application. The Federal Circuit held that all asserted claims were directed to the abstract idea of “collecting, analyzing, retrieving, and displaying information” and “customizing information.” For the first step, the court applied the principle that mental processes that can be performed in the human mind or using pencil and paper are abstract ideas. In analyzing representative claim 1 of the ‘933 patent, the court noted that each claimed step could be performed by humans—a store clerk could receive a customer’s question, consult a catalog to determine product location, inform the customer, and suggest another product based on the customer’s past inquiries. The court rejected Innovaport’s argument that the claims were directed to a specific organization of data or technical improvement, finding instead that the claims merely used computers as tools to implement conventional business practices. At step two, the court found no inventive concept in any of the asserted claims, either individually or in combination. The mobile devices were generic hardware that the specification described as routine technology, including telephones, walkie-talkies, headphones, and specialized eyewear. The court emphasized that mere recitation of generic computers cannot transform patent-ineligible abstract ideas into patent-eligible inventions. The court distinguished this case from others where claims were found patent-eligible because they presented technological solutions to technological problems, noting that here the patents addressed a business problem—helping customers shop more efficiently—using conventional technology, not computer functionality improvements. This decision confirms that improving user experience, without more, is insufficient to establish patent eligibility when the underlying claims are directed to abstract ideas implemented on generic computer hardware. The case illustrates how courts examine patent specifications to determine whether inventions represent genuine technological advances or merely apply computers to longstanding human activities. | 
