Federal Circuit Clarifies Patent Eligibility for Telecom Non-Uniform Constellation Tech

The Federal Circuit vacated and affirmed parts of a summary judgment on patent eligibility for non-uniform constellation tech patents.

The Federal Circuit issued a nuanced ruling on April 28, 2026, in Constellation Designs, LLC v. LG Electronics Inc., impacting the evolving landscape of patent eligibility for critical telecommunications technology.

• The patents in question address digital communication systems utilizing non-uniform constellations—methods for improving data transmission capacity in devices like televisions.
• The court divided the asserted claims into two groups: 'optimization claims' (from U.S. Patent Nos. 8,842,761 and 10,693,700) and 'constellation claims' (from U.S. Patent Nos. 11,019,509 and 11,018,922).
• 'Optimization claims' were deemed ineligible under § 101, as they merely described the abstract idea of optimizing a constellation for parallel decode capacity. The court wrote, "The specification cannot be used to import details from the specification if those details are not claimed."
• Conversely, 'constellation claims' were upheld for patent eligibility, credited for reciting specific, technological implementations—"recited specific non-uniform constellations with defined characteristics."
• The jury’s finding of infringement stood, awarding Constellation $1,684,469 in past damages from a $6.75 per-television royalty, a sum undisturbed by the appellate ruling.
• LG Electronics had challenged both the validity of the patents under § 101 and Constellation’s proof of infringement, but the court rejected LG’s motions for no damages and non-infringement.

This decision illustrates the Federal Circuit's ongoing refinement of the Alice/Mayo framework—providing clearer boundaries for patent counsel evaluating telecommunications inventions.