Federal Circuit IP
Constellation Designs, LLC v. LG Electronics Inc.
Constellation Designs, LLC v. LG Electronics Inc.
CAFC No. 2024-1822, Decided Apr. 28, 2026
(Lourie, Stoll, Oetken)
Background:
- E.D. Tex.: Constellation sued LG, alleging that LG’s TV products infringed patents relating to improving how digital information is transmitted over the air to televisions.
- The accused LG TVs used the ATSC 3.0 broadcast standard, which Constellation alleged practiced its patented constellation technology.
- The district court granted Constellation summary judgment that all nine asserted claims were patent eligible under § 101.
- The jury found infringement, willfulness, no invalidity, and awarded $1.6 million in past damages. LG appealed.
Issue: Whether the asserted claims were patent eligible under § 101, and whether infringement could be proven by relying on an industry standard for some claim limitations and product-specific evidence for others.
Holding: Vacated-in-part, affirmed-in-part, and remanded. The Federal Circuit held that the “optimization claims” were patent-ineligible, but the “constellation claims” were patent-eligible. The Court also affirmed the denial of JMOL of non-infringement, holding that a patentee may rely on standards-based proof for some limitations and product-specific evidence for others.
Federal Circuit Analysis:
- Eligibility — optimization claims: ineligible. The ’761 and ’700 patent claims were directed to QAM symbol constellations optimized for capacity using parallel decode capacity.
- At Alice step one, the claims were directed to the abstract idea of “optimizing” a constellation for PD capacity. The claims were result-oriented because they recited the desired optimized result but did not claim how to achieve it.
- Specification could not save missing claim limitations. Constellation argued that the specification disclosed an iterative optimization process. The Federal Circuit rejected that argument because § 101 focuses on the claims. Details disclosed in the specification do not save claims that omit the implementation details.
- At Alice step two, the Court found no inventive concept because Constellation’s alleged inventive concept was the abstract idea itself.
- At Alice step one, the claims were directed to the abstract idea of “optimizing” a constellation for PD capacity. The claims were result-oriented because they recited the desired optimized result but did not claim how to achieve it.
- Eligibility — constellation claims: eligible. The ’509 and ’922 patent claims were directed to specific non-uniform constellation structures, including constellations with overlapping point locations. These claims were patent eligible because they recited specific constellation configurations, not merely a desired optimization result.
- Infringement: LG argued that Constellation could not rely on the ATSC 3.0 standard for some limitations and product-specific evidence for others. The Federal Circuit rejected that argument. Under Fujitsu, standards-based proof can apply on a limitation-by-limitation basis when the relevant portion of the standard is sufficiently specific and mandatory, or when the accused product implements an optional portion of the standard.
Takeaways:
- Patent prosecutors:
- When claiming an optimization or improvement, consider drafting claims that recite how the result is achieved, not just the desired result. (Incl. concrete steps, parameters, constraints, or specific structures that implement the improvement.)
- For § 101: a detailed specification may not save broad, result-oriented claims.
- Litigators:
- Broad “optimized for” language can support a § 101 challenge: whether the claim merely states the goal—e.g., “optimized for better performance”—without limiting how the goal is achieved.