Federal Circuit Distinguishes Patent Eligibility Among Different Communications Systems Claims

In Constellation Designs, LLC v. LG Electronics Inc., et al., No 2024-1822 (Fed. Cir. Aug. 31, 2026), the Federal Circuit affirmed in-part and vacated in-part a decision of the United States District Court for the Eastern District of Texas that found LG infringed Constellation’s patents.

Constellation sued LG for infringement of four patents related to improved communication systems that rely on non-uniform satellite constellations (constellation is a term used to describe the possible symbols that can be transmitted by a typical digital communication system) to transmit digital information. The district court granted Constellation’s motion for summary judgment that all the asserted claims are patent eligible claims. After a jury found that LG infringed, the district court denied LG’s motion for judgment as a matter of law (JMOL) that Constellation improperly relied on industry standards to prove infringement.

On appeal, the Federal Circuit held that the district court incorrectly granted summary judgment as to two of Constellation’s patents directed to non-uniform constellations optimized for capacity. The Federal Circuit determined these claims are broad enough to cover a mathematical concept and describe key distinguishing elements only in a result-oriented way. The remaining two patents, on the other hand, which claim specific constellation arrangements, describe a particular solution and have enough specificity to survive the Alice analysis. The Federal Circuit also affirmed the district court’s determination that Constellation properly proved infringement based on industry standards and the district court’s denial of LG’s JMOL pertaining to damages or exclusion of expert testimony.