Federal Circuit Affirms That Ad Integration Patent Claims Are Ineligible Under § 101

By Haedar

Photo: HolgersFotografie / Pixabay

Abstract ideas about placing advertisements in digital media remain hard to patent in the United States. On 14 October 2026, the U.S. Court of Appeals for the Federal Circuit affirmed the dismissal of Piranha Media Distribution LLC's suit against Hulu, LLC, agreeing that the asserted patent claims are ineligible under 35 U.S.C. § 101 (Piranha Media Distribution LLC v. Hulu, LLC, No. 2025-1038).

The Central District of California had granted Hulu's motion to dismiss. On appeal, Circuit Judge Cunningham, joined by Judges Taranto and Hughes, held that claim 1 is directed to an abstract idea and does not contain an inventive concept under the Mayo/Alice framework. The Court found Piranha's remaining arguments unpersuasive and affirmed.

What the decision signals

Section 101 remains a powerful early defence against patents that describe business methods or information management with generic computing language. The Federal Circuit continues to resolve many of these cases at the pleadings stage, which can end litigation before discovery.

Indonesia comparison

Indonesian Patent Law No. 13 of 2016 excludes computer programs as such (subject to computer-implemented inventions) and business methods that have no technical character. We are not aware of an Indonesian decision that has applied a U.S.-style Alice analysis. Applicants claiming advertising or media systems in Indonesia should emphasise a concrete technical solution, not a commercial outcome alone.

Sources

• Federal Circuit opinion, Piranha Media Distribution LLC v. Hulu, LLC, No. 2025-1038 (14 October 2026)