British Telecommunications PLC v. IAC/InterActiveCorp

British Telecommunications v. IAC, decided August 5th, 2025. Judge William Bryson — a Federal Circuit judge sitting by designation in the District of Delaware — granted summary judgment that the sole remaining patent claim, directed to a method of updating a user's profile, was invalid under Section 101. Along the way, the court distilled Section 101 doctrine into a group of six governing principles. This is a district-court decision. Here's the brief.

British Telecommunications, or BT, sued IAC/InterActiveCorp and several related companies — including Match Group — back in 2018, asserting a number of claims across six patents. The Match Group defendants operate online dating services designed to match compatible individuals.

Over the life of the case, the patents fell away one by one. Some claims were dismissed early under Section 101; others were narrowed through reexamination and inter partes review. By the time of this decision, only a single claim remained: claim 10 of U.S. Patent No. 7,243,105.

The '105 patent describes a method of updating a user's profile based on personalized reasoning about the user's activity. In simplified terms, claim 10 starts with a profile built from a user's stated preferences under a first set of rules. It then applies a second set of rules — what the patent calls meta-rules — to reweight those preferences based on how the user actually behaves. And it uses an inference engine to infer and output an updated profile.

IAC moved for summary judgment that claim 10 was ineligible under Section 101. The court granted the motion, ending the long-running case.

The question was whether claim 10 is directed to patent-ineligible subject matter. Section 101 defines what may be patented.

The Supreme Court has read into that broad language an implicit exception for abstract ideas, and it supplies the two-step framework from Mayo and Alice. Step one asks whether a claim is directed to an abstract idea. If it is, step two asks whether the claim adds an inventive concept that transforms it into something patent-eligible.

Judge Bryson observed that neither the Supreme Court nor the Federal Circuit has defined "abstract idea" with a single, comprehensive test. Instead, he explained, what has emerged from the case law is a group of related principles for gauging whether a claim is directed to an abstract idea.

He set out the six principles that bore most directly on this case.

Applying those principles, the court held claim 10 directed to an abstract idea at step one. Stripped to its essentials, the court said, the claim describes a process that could easily be performed in the human mind — much as a salesman, hearing a customer state a preference and then watching the customer's behavior, revises his sense of what the customer really wants. The court placed the claim in a familiar category.

Drawing on Federal Circuit decisions about matchmaking and targeted advertising — Trinity Info Media, Broadband iTV, and others — the court found claim 10 did no more than collect information about a person, analyze it, and update the person's profile. It rejected BT's argument that the claim improved computer technology: the inference engine used a computer merely as a tool, and the patent conceded that inference engines themselves were nothing new. The claim's breadth was largely functional, and its sweeping preemptive potential confirmed its abstraction.

At step two, BT identified "personalization" as the inventive concept. But personalization, the court held, was the very abstract idea it had already identified — and an abstract idea cannot supply its own inventive concept. Implementing it on generic computer components added nothing.

British Telecommunications v. IAC is a district-court decision, not binding precedent. Its notable feature is methodological. Rather than reach for a single definition of "abstract idea," Judge Bryson gathered the governing case law into six recurring principles — organizing human activity, performing human tasks on a computer, improvements to computer technology, collecting and analyzing information, functional claiming, and preemption — and applied them in sequence. Applied to a claim for updating user profiles in fields like matchmaking and targeted advertising, those principles pointed to ineligibility at both steps of Alice.

British Telecommunications v. IAC, 2025 WL 2240699, decided August 5th, 2025. I'm Kyle Coleman. Thanks for watching.