Show Your Work: To Survive 101, Federal Circuit Holds That Result-Oriented Patent Claims Must Specify How to Achieve a Result, and Expands the Infringement Proof Toolkit for Products Implementing Portions of a Standard

In Constellation Designs, LLC v. LG Electronics Inc., No. 2024-1822 (Fed. Cir. Apr. 28, 2026), the U.S. Court of Appeals for the Federal Circuit distinguished between two sets of claims under a Section 101 analysis, invalidating one set as result-oriented “optimization” claims that did not recite how to achieve such optimization, but upholding the other set as patent-eligible for reciting specific configurations with defined parameters. The court also confirmed that patentees may prove infringement by combining standards-based and product-specific evidence on a limitation-by-limitation basis.

Plaintiff Constellation alleged infringement of four patents by LG’s televisions that are compatible with an over-the-air broadcast television standard from the Advanced Television Systems Committee (ATSC) called ATSC 3.0, and specifically, protocol A/322 of the standard, which governs the physical layer of signals transmitted by broadcasters.  The asserted patents involve communication systems that use non-uniform constellations with increased capacity compared to conventional, uniform constellations operating within a similar signal-to-noise ratio band. Within the context of the asserted patents, “[t]he term ‘constellation’ is used to describe the possible symbols that can be transmitted by a typical digital communication system.” Traditionally, engineers designed uniform constellations to maximize the minimum distance between constellation points (d_min), as it was believed to result in improved capacity. The inventors, however, rather than optimizing d_min, constructed non-uniform constellations by optimizing the constellation’s capacity — specifically, they optimized parallel decode (PD) capacity, which measures information successfully transmitted from mapper to demapper across a communication channel.

The district court granted summary judgment of Section 101 eligibility for all claims, characterizing the technical problem as data loss in over-the-air transmission and the claimed solution as a communication system using a PD-capacity-optimized constellation. A jury then found infringement of at least one asserted claim of each asserted patent, found that the infringement was willful, and awarded Constellation past damages at a per-television royalty rate based on third-party licenses.

The Federal Circuit distinguished between the “optimization claims” (which recited constellations optimized for PD capacity) and the “constellation claims” (which recited specific non-uniform constellations). Regarding the optimization claims, the court vacated the finding of Section 101 eligibility. Under Alice step one, the court found that the representative claim’s critical “wherein” clause is described in a result-oriented way, reciting a constellation optimized for PD capacity such that it achieves a better capacity when compared to the prior art constellations that were maximized for d_min. The clause, however, did not recite how to achieve such a constellation “optimized” for PD capacity. Therefore, the claim is directed to the abstract idea of “optimizing” a constellation for PD capacity, covering all ways of achieving a recited result. Although the specification details an iterative optimization process, the court underscored that the Section 101 inquiry focuses on the claims themselves, and details from the specification may not be imported into the claims.

Under Alice step two, the court was unpersuaded by Constellation’s arguments that there was an inventive concept because the inventors were credited as the first to develop non-uniform constellations optimized for PD capacity, finding that this conflated the separate novelty and obviousness inquiries under Sections 102 and 103 with the search for an inventive concept. The court found that Constellation identified no claim elements, either individually or as an ordered combination, that transform the nature of the claim, and that its alleged inventive concept was simply the abstract idea itself restated.

In contrast, the court affirmed the finding of Section 101 eligibility for the constellation claims. Instead of claiming the abstract idea of “optimizing” a constellation for capacity without limiting the optimization to any meaningful process or constraints, the court found under Alice step one that the constellation claims are directed to specific constellations that the inventors developed using the techniques described in the specifications. Such distinction “makes all the difference,” as it results in a claim directed to solving a particular technological problem (i.e., overcoming capacity constraints to improve coding gains) using a particular technological solution (i.e., specific, non-uniform constellations with overlapping constellation point locations). 

Regarding infringement, at trial, Constellation relied on the ATSC 3.0 and A/322 standards to satisfy some claim limitations while using product-specific evidence for others. LG argued that under Fujitsu Ltd. v. Netgear Inc., 620 F.3d 1321 (Fed. Cir. 2010), standards-based proof is permitted only when the standard satisfies every limitation of the claim in its entirety. The Federal Circuit disagreed, extending Fujitsu on a limitation-by-limitation basis, holding that a patentee may prove satisfaction of an individual claim limitation through standards-based evidence if (1) the relevant portion of the standard is sufficiently specific to show that practicing it would always result in practicing that limitation, and (2) the relevant portion is mandatory or, if optional, there is evidence the accused device implements it.

The court’s distinction between the vacated optimization claims and the surviving constellation claims is a powerful reminder that no matter how detailed the specification is in describing the underlying invention, claims that recite a desired outcome must also recite specific processes, parameters, or structures to achieve such desired outcome, or else risk vulnerability under Section 101. In addition, for patent litigants, the extension of Fujitsu to a limitation-by-limitation basis meaningfully expands the evidentiary toolkit available to patentees asserting standard-related patents, permitting flexible, element-specific proof strategies without sacrificing infringement theories for claim elements not directly addressed by a standard.