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Loeb & Loeb secured a significant appellate victory for Teads, an omnichannel communication platform, in a decision in which the U.S. Court of Appeals for the Federal Circuit affirmed a district court ruling holding four Yieldmo, Inc. patents directed to interactive advertising invalid under section 101 of the Patent Act as drawn to patent-ineligible subject matter.
In Yieldmo, Inc. v. Teads, Inc., et al., Yieldmo sued Teads in the U.S. District Court for the Southern District of New York, alleging infringement of four patents, which concern customizing advertisements based on a user's real-time webpage activity, such as scrolling. At the outset of the litigation, Loeb moved to dismiss under Rule 12(b)(6) of the Federal Rules of Civil Procedure, arguing that the patents were invalid under Section 101 because they were directed to the abstract idea of serving responsive digital advertisements and supplied no inventive concept.
On July 21, 2025, U.S. District Judge Paul A. Engelmayer agreed, granting Loeb’s motion and dismissing the case. The court held that the patents claimed "nothing more than the quotidian idea of customizing advertising based on the user's webpage activity." The court explained that the patents were directed to a method of advertising, not to any improvement in digital hardware or software, and that they did not disclose a technical solution, as their claims merely recited steps that computers commonly perform.
Yieldmo then appealed to the Federal Circuit. On Oct. 13, 2026, a Federal Circuit panel affirmed the district court's judgment without opinion under Federal Circuit Rule 36 and awarded Teads its costs.
The Loeb team included Bill Kramer, deputy chair of the firm’s Patent Litigation & Counseling department, and partners Ryan Hagglund and William Voller, Litigation partner Ali Schaller, associate Celeste Kabemba and paralegals Barbara Summers and Amber Ordonez.
In Yieldmo, Inc. v. Teads, Inc., et al., Yieldmo sued Teads in the U.S. District Court for the Southern District of New York, alleging infringement of four patents, which concern customizing advertisements based on a user's real-time webpage activity, such as scrolling. At the outset of the litigation, Loeb moved to dismiss under Rule 12(b)(6) of the Federal Rules of Civil Procedure, arguing that the patents were invalid under Section 101 because they were directed to the abstract idea of serving responsive digital advertisements and supplied no inventive concept.
On July 21, 2025, U.S. District Judge Paul A. Engelmayer agreed, granting Loeb’s motion and dismissing the case. The court held that the patents claimed "nothing more than the quotidian idea of customizing advertising based on the user's webpage activity." The court explained that the patents were directed to a method of advertising, not to any improvement in digital hardware or software, and that they did not disclose a technical solution, as their claims merely recited steps that computers commonly perform.
Yieldmo then appealed to the Federal Circuit. On Oct. 13, 2026, a Federal Circuit panel affirmed the district court's judgment without opinion under Federal Circuit Rule 36 and awarded Teads its costs.
The Loeb team included Bill Kramer, deputy chair of the firm’s Patent Litigation & Counseling department, and partners Ryan Hagglund and William Voller, Litigation partner Ali Schaller, associate Celeste Kabemba and paralegals Barbara Summers and Amber Ordonez.
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Deputy Chair, Patent Litigation & Counseling -
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