Fox defeated Recentive's machine-learning patent appeal in one of 2025's most important AI-adjacent eligibility decisions.
The patents claimed using machine learning to generate network maps and schedules for television broadcasts and live events. The Federal Circuit affirmed dismissal, holding that applying generic machine-learning techniques in a particular environment did not add an inventive concept.
The opinion is likely to be cited often because it addresses the core mistake in many AI patent filings: treating the presence of machine learning as the technical improvement.
For AI builders and patent prosecutors, the path forward is narrower. Claims need to identify an improvement to the model, training process, data structure, or computing system, not just a business workflow performed with machine learning.