The Federal Circuit affirmed the Central District of California's grant of Hulu, LLC's motion to dismiss in Piranha Media Distribution LLC v. Hulu, LLC, No. 2025-1038 (Fed. Cir. Oct. 14, 2026) (nonprecedential). Piranha had sued for infringement of U.S. Patent Nos. 10,986,403 and 11,463,768, which relate to integrating advertisements into digital media. The district court concluded the asserted patents do not claim patent-eligible subject matter under 35 U.S.C. 101. Circuit Judge Cunningham wrote for a panel that also included Circuit Judges Taranto and Hughes (Op. 1-2).

What was before the court

Piranha asserted the two patents in January 2024. The '768 patent is a continuation of the '403 patent. The parties agreed that claim 1 of the '403 patent is representative of the claims of both patents for eligibility. Claim 1 recites a digital media player device with processors, a user interface input, an "intersplicer" that sequences digital media and advertising content and adaptively modifies advertising insertion points when the user changes play position, a user interface output, and memory that can disable volume or navigation controls while a required part of the advertising content plays (Op. 2-5).

Hulu moved to dismiss under section 101 and also argued that a 2020 Patent Trial and Appeal Board decision on earlier claims in the '403 application's family precluded eligibility litigation. The district court rejected the preclusion argument, then dismissed after finding claim 1 directed to abstract ideas and lacking an inventive concept (Op. 5-6).

What the Federal Circuit held

At Alice/Mayo step one, the court held that claim 1 is directed to the abstract idea of preventing skipping advertisements by receiving, organizing, displaying, and controlling access to data. It reasoned that the claim uses conventional operations of generic computer components and does not solve a technological problem unique to computers or networks. At step two, it held that the claim elements, including the intersplicer's sequencing and adaptive resequencing of advertising insertion points under "adaptive preference rules," recite well-understood, routine, conventional activities and do not supply an inventive concept (Op. 7-15).

The court did not reach whether the Board decision has any preclusive effect, because the district court did not rely on preclusion as the basis for its decision. The judgment of the district court was affirmed (Op. 15-16).