Federal Circuit Affirms § 101 Dismissal in Distracted Driving Patent Suit: TJTM Technologies v. Google

On May 5, 2026, the U.S. Court of Appeals for the Federal Circuit (CAFC) affirmed the dismissal of a patent infringement suit in TJTM Technologies, LLC v. Google LLC, holding that the asserted claims of U.S. Patent No. 8,958,853 are directed to patent-ineligible subject matter under 35 U.S.C. § 101. The nonprecedential decision was authored by Judge Chen and joined by Judges Dyk and Stark.

The Asserted Patent

The ‘853 patent claims a mobile device that suppresses incoming notifications—calls, texts, and emails—when placed in an “inactive mode,” while automatically transmitting an away message to the sender. The patent’s central use case involves a smartphone automatically entering inactive mode upon pairing with a vehicle, functioning as a hands-free, do-not-disturb feature designed to prevent distracted driving.

TJTM Technologies filed suit in February 2024, alleging that Google Android’s distracted driving prevention features infringed the ‘853 patent. Google moved to dismiss, and the Northern District of California applied the two-step analytical framework established in Alice Corp. Pty. Ltd. v. CLS Bank International.

The Alice Two-Step Analysis

Under Alice step one, the district court found that representative claim 1 was directed to the abstract idea of “screening notifications.” The court granted TJTM leave to amend and address step two. After TJTM filed a first amended complaint in September 2024, the district court concluded that each recited component was generic and well-known, combined in a conventional fashion, and dismissed the action.

On appeal, TJTM argued the district court erred in its step one analysis, contending that the patent addressed a genuine technological problem—distracted driving—with a technological solution. TJTM drew analogies to Contour IP Holding LLC v. GoPro, Inc. and similar Federal Circuit decisions that found patents directed to technological solutions to be eligible.

The Federal Circuit’s Reasoning

The CAFC was unpersuaded. Writing for the panel, Judge Chen observed that claim 1 describes a different operational mode for a mobile phone without reciting any change to the underlying mobile phone technology itself. While the claimed invention may benefit users by suppressing notifications during driving, the court held that “that extra user benefit alone does not amount to a ‘technological improvement’ under our precedent.”

The Federal Circuit distinguished the ‘853 patent from cases like Enfish, LLC v. Microsoft Corp., where the claimed invention was directed to a specific structural improvement to computer functionality. TJTM’s claims, the court concluded, went no further than adding a communication-suppression function to an otherwise conventional phone, placing them squarely within abstract idea territory.

On Alice step two, TJTM contended that the specific ordering and combination of claim limitations—entering inactive mode, detecting an incoming communication, suppressing a notification, and transmitting an away message—constituted a non-routine, inventive concept. The CAFC disagreed. Citing Trinity Info Media, LLC v. Covalent, Inc., the court noted that conclusory allegations regarding an inventive concept are insufficient to defeat a Rule 12(b)(6) motion to dismiss. The court held that the claimed sequence of steps is “a description of the abstract idea of suppressing notifications on a cell phone,” and that “merely applying an abstract idea to a ‘particular technological environment’ is not enough to transform the underlying idea into something patent eligible.”

Practical Implications

Although nonprecedential, the decision reinforces a consistent line of Federal Circuit § 101 jurisprudence: patent claims that apply an abstract function to a conventional device—without reciting structural improvements to the underlying technology—remain vulnerable to dismissal at the pleading stage under Alice.

For patent practitioners in the mobile technology and automotive connectivity space, the ruling underscores the importance of drafting claims that articulate specific structural or functional improvements to hardware or software architecture, rather than relying on use-case benefits such as safety or user convenience as the basis for eligibility.

Companies holding patents in distracted driving prevention technology—a space occupied by Apple, Google, and major automakers—may wish to audit their portfolios for comparable § 101 vulnerabilities in light of this decision.