Opinion

Tjtm Technologies, LLC v. Google LLC

Court
Court of Appeals for the Federal Circuit
Filed
May 5, 2026
Status
Unpublished
Cited by
0 cases
Authority
More cited than 40.4%

determining that the claimed inven- tion was directed to a specific self-referential table for a computer database and not merely “the concept of organiz- ing information using tabular formats”

How later courts described this case

  • determining that the claimed inven- tion was directed to a specific self-referential table for a computer database and not merely “the concept of organiz- ing information using tabular formats”
  • disregarding conclusory allegations regarding a patent claim’s inventive concept when evaluating a com- plaint under Rule 12(b)(6)

Written by the judges who cited it.

The opinion

Case: 25-1218 Document: 42 Page: 1 Filed: 05/05/2026

NOTE: This disposition is nonprecedential.

United States Court of Appeals

for the Federal Circuit

______________________

TJTM TECHNOLOGIES, LLC,

Plaintiff-Appellant

v.

GOOGLE LLC,

Defendant-Appellee

______________________

2025-1218

______________________

Appeal from the United States District Court for the

Northern District of California in No. 3:24-cv-01232-TLT,

Judge Trina L. Thompson.

______________________

Decided: May 5, 2025

______________________

BLAIR V. KITTLE, Cotchett, Pitre & McCarthy, LLP,

Burlingame, CA, argued for plaintiff-appellant. Also rep-

resented by JOSEPH W. COTCHETT, VASTI S. MONTIEL.

JONATHAN IRVIN TIETZ, Perkins Coie LLP, Washington,

DC, argued for defendant-appellee. Also represented by

DAN L. BAGATELL, Hanover, NH.

______________________

Before DYK, CHEN, and STARK, Circuit Judges.

Case: 25-1218 Document: 42 Page: 2 Filed: 05/05/2026

2 TJTM TECHNOLOGIES, LLC v. GOOGLE LLC

CHEN, Circuit Judge.

TJTM Technologies, LLC (TJTM) appeals the United

States District Court for the Northern District of Califor-

nia’s grant of Google LLC’s (Google) motion to dismiss.

TJTM Techs., LLC v. Google LLC, No. 24-CV-01232-TLT,

2024 WL 5106443, at *6 (N.D. Cal. Oct. 22, 2024) (Deci-

sion). Below, the district court determined that repre-

sentative claim 1 of TJTM’s U.S. Patent No. 8,958,853 (’853

patent) (1) is directed to an ineligible abstract idea and

(2) lacks an inventive concept. Thus, the district court de-

termined that the ’853 patent claims were ineligible under

35 U.S.C. § 101, and TJTM could not survive a motion to

dismiss its patent infringement action. Because we agree

that the ’853 patent claims are ineligible under § 101, we

affirm.

BACKGROUND

TJTM is the owner of the ’853 patent. The ’853 patent

relates to “a mobile device including functionality for sup-

pressing user notifications of communications received by

the mobile device.” ’853 patent col. 1 ll. 14–18. The speci-

fication discloses a generically-described mobile phone hav-

ing an “inactive mode” which suppresses incoming

notifications of calls, texts, emails, etc. and automatically

notifies the sender with an “away message.” Id. col 1 l. 66

– col. 2 l. 1.

Independent claim 1 is representative and recites:

A mobile device, comprising:

a wireless communication module;

a processor, controlling the wireless communica-

tion module; and

a memory controlled by the processor, the memory

including instructions that when executed by the

processor cause the processor to perform the steps

of:

Case: 25-1218 Document: 42 Page: 3 Filed: 05/05/2026

TJTM TECHNOLOGIES, LLC v. GOOGLE LLC 3

providing a graphical user interface

through which a user customizes one or

more functions of the mobile device when

placed in an inactive mode;

receiving a user selection to automatically

initiate the inactive mode in response to

the pairing of the mobile device with a ve-

hicle;

receiving a user selection of an away mes-

sage to use when the mobile device is in in-

active mode;

in response to the pairing of the mobile de-

vice and the vehicle, automatically initiat-

ing a process to place the mobile device in

inactive mode;

when the mobile device is in inactive mode,

in response to receiving a communication

from the wireless communication module,

transmitting the user selected away mes-

sage via the wireless module and suppress-

ing one or more sound, visual, or vibration

communication cues that would have ac-

companied the communication had the mo-

bile device not been in inactive mode.

Id. at col. 12 ll. 36–61.

On February 29, 2024, TJTM filed a complaint alleging

certain features implemented in Google Android phones to

prevent distracted driving infringed TJTM’s ’853 patent.

Decision, 2024 WL 5106443, at *1. In response, Google

filed a motion to dismiss, which the district court granted

after applying the two-step framework outlined in Alice

Corp. Pty. v. CLS Bank International, 573 U.S. 208 (2014).

For its Alice step one analysis, the court found that

Case: 25-1218 Document: 42 Page: 4 Filed: 05/05/2026

4 TJTM TECHNOLOGIES, LLC v. GOOGLE LLC

representative claim 11 was directed to the abstract idea of

“screening notifications.” J.A. 253. After finding that

claim 1 lacks an inventive concept under Alice step two, the

court granted TJTM leave to amend its pleadings to ad-

dress step two. For step one, the court found amendment

was futile. See id. at 258–59.

On September 3, 2024, TJTM filed its first amended

complaint, and Google responded by filing a second motion

to dismiss. Decision, 2024 WL 5106443, at *1.

After revisiting its Alice step two analysis, the district

court agreed with Google that each of the components in

claim 1 was generic and well-known, and combined in con-

ventional fashion. See id. at *6. Thus, the court deter-

mined that TJTM’s allegations in its amended complaint

were insufficient to withstand Google’s patent-eligibility

challenge and dismissed TJTM’s infringement case.

TJTM timely appealed. We have jurisdiction under

28 U.S.C. § 1295(a)(1).

DISCUSSION

On appeal, TJTM first argues the district court erred

in its step one analysis. According to TJTM, mobile devices

in normal operation can cause distracted driving, and “the

patent addresses this technological problem with a techno-

logical solution.” Appellant Br. 9.

In its first motion to dismiss order, the district court

determined that claim 1’s language describes little more

than “screening notifications” for a mobile device. J.A. 253.

For further support, the district court noted the specifica-

tion highlighted the problem of distracted driving and its

1 TJTM does not dispute that claim 1 is representa-

tive of all the claims of the ’853 patent, i.e., claims 1–9. See

generally Appellant Br.

Case: 25-1218 Document: 42 Page: 5 Filed: 05/05/2026

TJTM TECHNOLOGIES, LLC v. GOOGLE LLC 5

proposed solution was to simply suppress communications.

See id. (citing ’853 patent col. 2 ll. 2–3, 46–56).

TJTM’s argument does not dispute any of these find-

ings. Instead, TJTM suggests that claim 1 is analogous to

the claims found eligible in Contour IP Holding LLC v. Go-

Pro, Inc., 113 F.4th 1373 (Fed. Cir. 2024), and similar cases

in which this court determined claims “directed to a tech-

nological solution to a technological problem” were not di-

rected to patent ineligible subject matter. See Appellant

Br. 12–16. This argument is unavailing.

As the district court observed, claim 1 describes “[t]he

method of mobile devices pairing with vehicles to automat-

ically enter inactive mode.” J.A. 253. While the method

may improve a user’s experience via a mobile device auto-

matically entering inactive mode, that extra user benefit

alone does not amount to a “technological improvement”

under our precedent. The claimed invention merely recites

a different mode of operation for a mobile phone without

reciting any change to the underlying mobile phone tech-

nology. Cf. Enfish, LLC v. Microsoft Corp., 822 F.3d 1327,

1337 (Fed. Cir. 2016) (determining that the claimed inven-

tion was directed to a specific self-referential table for a

computer database and not merely “the concept of organiz-

ing information using tabular formats”). TJTM’s argument

fails to suggest that the claims of the ’853 patent are di-

rected to anything other than an abstract idea of adding a

communication-suppression function to a phone.

TJTM also disputes the district court’s step two analy-

sis. TJTM contends the district court was incorrect in find-

ing the claim limitations—which TJTM articulates as a

“specific combination” of steps that “achieve[] the patent[’s]

intended result of preventing distracted driving”—are “or-

dered in a conventional fashion.” Appellant Br. 18.

In its second motion to dismiss order, the district court

concluded that claim 1 recites “generic and well-known”

components “ordered in a conventional fashion.” Decision,

Case: 25-1218 Document: 42 Page: 6 Filed: 05/05/2026

6 TJTM TECHNOLOGIES, LLC v. GOOGLE LLC

2024 WL 5106443, at *6. We agree with the district court’s

analysis.

TJTM’s arguments are merely conclusory assertions

that claim 1 recites an inventive concept. TJTM does not

suggest how or why claim 1’s sequence2 of “placing [a] com-

munications device in inactive mode,” “detecting an incom-

ing communication,” “suppressing [a] notification to [a]

user,” and “transmitting an away message to the sender of

the communication,” Appellant Br. 19, is anything more

than a description of the abstract idea of suppressing noti-

fications on a cell phone. We have previously “explained

that merely applying an abstract idea to a ‘particular tech-

nological environment,’ . . . [i]s not enough to transform

the underlying idea into something patent eligible.” Cell-

spin Soft, Inc. v. Fitbit, Inc., 927 F.3d 1306, 1319 (Fed. Cir.

2019) (internal citation removed).

Conclusory allegations as to an inventive concept are

insufficient to defeat a motion to dismiss. See Trinity Info

Media, LLC v. Covalent, Inc., 72 F.4th 1355, 1365–66 (Fed.

Cir. 2023) (disregarding conclusory allegations regarding a

patent claim’s inventive concept when evaluating a com-

plaint under Rule 12(b)(6)). Before the district court,

TJTM relied on conclusory statements, and it continues to

do so in this appeal. Therefore, like the district court, we

conclude that representative claim 1 lacks an inventive

concept.3 Accordingly, the claims of the ’853 patent are pa-

tent ineligible under § 101.

2 TJTM lists five steps as part of the ’853 patented

invention. See Appellant Br. 19. However, its fifth step,

“upon completion of the inactive mode, notifying the user

of missed communications,” is not disclosed in representa-

tive claim 1. Thus, we omit this step from our discussion.

3 Though TJTM suggested in its briefs that “pairing

the mobile device with the vehicle and automatically

Case: 25-1218 Document: 42 Page: 7 Filed: 05/05/2026

TJTM TECHNOLOGIES, LLC v. GOOGLE LLC 7

We have reviewed the remainder of TJTM’s arguments

and find them unpersuasive. For the foregoing reasons, we

affirm.

AFFIRMED

putting it in inactive mode” is an inventive concept, see Ap-

pellant Br. 19, at oral argument TJTM effectively conceded

that, at the time of invention, “pairing the mobile device”

was not an inventive part of the ’853 patent. See Oral Arg.

at 9:29–10:59, available at

https://www.cafc.uscourts.gov/oral-arguments/25-1218_04

062026.mp3 (agreeing that “methods of pairing” were

known in the field and were not a necessary part of the as-

serted claim).

This is a copy of a public record, reproduced as it was published. It is not legal advice, and it may not be the version a court would rely on. Check the official source before you cite it.

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