Recentive sets the baseline rule for machine learning eligibility

Recentive Analytics, Inc. v. Fox Corp., 134 F.4th 1205 (Fed. Cir. Apr. 18, 2025), No. 2023-2437

Four patents claimed the use of machine learning models to generate television broadcast schedules and network maps. The Federal Circuit affirmed dismissal under § 101 and held that claims doing no more than applying established methods of machine learning to a new data environment, without disclosing improvements to the machine learning models themselves, are ineligible. The court left open how large an improvement must be and how much empirical support a patentee must supply.