Applying a known machine learning technique to a new field is still abstract

Rensselaer Polytechnic Institute v. Amazon.com, Inc., No. 24-1725 (Fed. Cir. Feb. 24, 2026) (Dyk, J.); U.S. Pat. No. 7,177,798

The patent claimed a method of processing natural language input using case-based reasoning, a machine learning technique that resolves ambiguity by drawing on stored historical examples in a metadata database. The Federal Circuit affirmed ineligibility, holding that generic use of artificial intelligence without other parameters is abstract, and that a conventional application of case-based reasoning, even to a novel environment, does not become eligible because the environment is new. The specification's own description of the database elements as well known in the art was used against the patentee at step two.