Federal Circuit Affirms AR Patents Invalid Under Section 101 in NantWorks v. Niantic

The U.S. Court of Appeals for the Federal Circuit (CAFC) on April 23, 2026, affirmed a district court ruling that claims of two augmented reality (AR) patents held by NantWorks LLC are directed to abstract ideas and therefore patent-ineligible under 35 U.S.C. § 101. The case, NantWorks, LLC v. Niantic, Inc., No. 24-2216, involved AR technology underlying Niantic’s popular location-based games Pokémon GO and Harry Potter: Wizards Unite. The nonprecedential opinion was authored by Judge Cunningham.

Patent Background and Litigation History

NantWorks sued Niantic in the Northern District of California in 2020, alleging infringement of at least claim 1 of U.S. Patent Nos. 10,664,518 (the ‘518 patent) and 10,403,051 (the ‘051 patent). Both patents cover technology for controlling the display of AR content objects in an environment based on location data and contextual information about the surroundings.

The district court held that the asserted claims of both patents were directed to abstract ideas under step one of Alice Corp. v. CLS Bank International, 573 U.S. 208 (2014), and that no inventive concept existed under step two. NantWorks appealed to the CAFC.

The ‘518 Patent: Tessellated Tiles Fail to Supply an Inventive Concept

The district court characterized the ‘518 patent claims as directed to the abstract idea of receiving information about a location and displaying materials based on that information. At Alice step two, it found no inventive concept that rendered the claims eligible.

On appeal, NantWorks argued the district court oversimplified the relevant claim elements by failing to account for steps involving tessellated tiles, tile subareas, areas of interest, and AR content objects. NantWorks further contended that tessellated tiles and tile subareas provided the necessary inventive concept.

The CAFC rejected these arguments. The court found that using tessellated tiles and tile subareas to select an area on a map and generate a view of interest was part of the abstract idea itself, not a feature that transformed it into patent-eligible subject matter. The claimed elements, individually or in combination, represented conventional steps insufficient to supply the inventive concept required under Alice step two.

The ‘051 Patent: Context Assessment as Organization of Human Activity

For the ‘051 patent, the district court found the claims describe a system to determine contextual information about the environment and alter the presence of a relevant AR object accordingly, characterizing this as organizing human activity.

The CAFC upheld this characterization. NantWorks argued the district court ignored expert testimony establishing the claimed system was unconventional. The CAFC disagreed, noting the claims invoked conventional components, and that NantWorks’ expert report merely repeated unclaimed passages from the specification or offered conclusory statements—neither of which sufficed to establish a triable factual issue under Berkheimer v. HP Inc., 881 F.3d 1360 (Fed. Cir. 2018).

Section 101 and AR Technology: A Continuing Challenge

This decision adds to a growing body of Federal Circuit precedent in which AR and location-based technology claims have struggled to clear the patent-eligibility bar under Alice. The core functional elements of AR systems—processing location data, assessing environmental context, and rendering content accordingly—have repeatedly been held ineligible when claimed at a level of generality that does not tie them to a specific technical improvement.

While nonprecedential, the decision reinforces guidance for AR patent practitioners: claims must identify a specific technical problem and its solution with sufficient particularity. General descriptions of receiving location data and presenting context-responsive AR content are unlikely to survive eligibility scrutiny without a more precise articulation of the technical mechanism involved.

NantWorks has been active in enforcing its AR patent portfolio across multiple proceedings. The district court rulings, now affirmed on appeal, effectively close this chapter of enforcement against Niantic.