Case Explained: ETISON LLC v. HIGHLEVEL, INC

Court: United States Court of Appeals for the Federal Circuit

Filed: 2026-07-02

The Federal Circuit affirmed the District Court for the District of Delaware’s judgment dismissing Etison LLC’s patent infringement lawsuit for failure to state a claim. The court held that all claims of U.S. Patent Nos. 10,846,357 and 11,361,047 are invalid under 35 U.S.C. § 101 as directed to an unpatentable abstract idea lacking an inventive concept. The court applied the two-step *Alice* test for patent eligibility. At step one, the parties agreed the claims were directed to the abstract idea of “filtering information based on user preferences to arrive at a final result.” At step two, the court analyzed whether the claims contained an “inventive concept” sufficient to transform the abstract idea into a patent-eligible application. The court found that the claims merely recite generic computer functions—such as displaying images, configuring webpages, receiving input, and editing pages—and rely on functional, result-oriented language without describing a specific implementation that improves computer functionality. The court further determined that limitations regarding “one or more triggers” introduced only conventional computer activities. Regarding procedural grounds, the court noted that while the District Court erred by treating claim 1 of the ‘357 patent as representative of all claims without adequately addressing ClickFunnels’ argument that dependent claims 13 and 16 contained a distinctive “one or more triggers” limitation, this error was harmless. The District Court had effectively analyzed those specific limitations under step two of the *Alice* test and correctly concluded they lacked an inventive concept. Consequently, the dismissal stands, rendering the patents-in-suit invalid as a matter of law.

Do It For The Case Law is a news reporting service. Nothing in this episode constitutes legal advice.