Constellation Designs, LLC v. LG Electronics Inc.

Constellation Designs v. LG Electronics, in an opinion by Judge Stoll, issued in April 2026 and modified on rehearing on August 31st. A precedential panel of the Federal Circuit split the patent-eligibility question down the middle. Claims to signal constellations optimized for a result were abstract, like the telegraph claim struck down in O'Reilly v. Morse. Claims to specific constellations were eligible. The court also affirmed infringement and damages. Here's the brief.

Digital communication systems convert bits into analog signals using a constellation, a set of symbols plotted by amplitude and phase. Conventional designs spaced those points uniformly to maximize the minimum distance between them. Constellation's inventors instead built non-uniform constellations, optimized iteratively for a capacity measure called parallel decode capacity.

Constellation sued LG, alleging that LG televisions compatible with the ATSC 3.0 broadcast standard infringed four patents. The court of appeals sorted the claims into two groups. The optimization claims recite a constellation optimized for capacity using parallel decode capacity. The constellation claims recite specific non-uniform constellations.

The district court granted summary judgment that all the claims were eligible. A jury found willful infringement and awarded about $1.68 million, and the court denied LG's post-trial motions. LG appealed.

Eligibility under section 101 follows the Supreme Court's two-step framework in Alice. At step one, the question is whether the claim is directed to an abstract idea. If so, step two asks whether the claim's elements, individually or in combination, supply an inventive concept that transforms it into a patent-eligible application.

The court emphasized that the inquiry focuses on the claims. A specification may illuminate a claim's focus, but reliance on it must yield to the claim language, and details that are not claimed cannot be imported from the specification.

The optimization claims failed. Claim 17 does not say how to achieve a constellation optimized for parallel decode capacity. It describes that distinguishing element by its result.

The court acknowledged the issue was close. But the claim omitted the iterative process the specification described, and the inventor conceded that non-uniform constellations and parallel decode capacity were already known. At step two, Constellation's asserted inventive concept was the abstract idea itself. Arguments about novelty and nonobviousness, the court said, conflate separate inquiries.

The constellation claims came out the other way.

Claim 21 of the ’509 patent recites unequally spaced point locations, each point with a different label, and at least two points sharing a location. That is a particular technological solution to a particular technological problem, specific enough to pass step one.

On infringement, the court held that a patentee may prove some claim limitations through an industry standard and others through product-specific evidence. It extended its Fujitsu framework to individual limitations, and it affirmed the damages award.

Constellation Designs draws the section 101 line within a single patent family. A claim that recites a desired result, and covers every way of reaching it, is directed to an abstract idea, however technical the specification. A claim that recites the specific structure the inventors arrived at is not. The decision roots that distinction in O'Reilly v. Morse and ChargePoint, and it confirms that eligibility is judged by what the claims recite.

Constellation Designs, LLC v. LG Electronics Inc., No. 2024-1822, opinion modified August 31st, 2026. I'm Kyle Coleman. Thanks for watching.