Western District of Texas Splits the Difference on Patent Eligibility
On April 10, 2026, the U.S. District Court for the Western District of Texas issued a split ruling in VE Opening LLC v. Sprinklr, Inc., No. 1:25-cv-01736-ADA, that underscores a critical lesson for patent owners and technology companies alike: how narrowly you draft your patent claims can mean the difference between surviving an early challenge and losing your case before it really begins. The court dismissed the asserted patent's broad independent claim as abstract and ineligible under Section 101 of the Patent Act, but allowed three narrower dependent claims to proceed, finding they recited specific enough technological improvements to clear the bar.
What Happened
VE Opening sued Sprinklr for infringing U.S. Patent No. 9,916,079, which covers a method for enabling applications on a computing device to share information. Sprinklr moved to dismiss under Rule 12(b)(6). The court agreed with Sprinklr on the broad independent claim. Using the Alice framework, the court found this claim directed to "collecting information, analyzing it, and displaying results." The court observed that a "person manually looking through their own files, emails, and calendar, identifying matches for a specific entry, and writing down a reference to one of them performs exactly what claim 1 recites." At Alice step two, the claim failed as well: "the claim does not specify how candidate elements are determined nor does it require a new form of display or any non-conventional hardware."
Why the Dependent Claims Survived
The outcome flipped for dependent claims 4 through 6. Each added concrete constraints that the court found transformed the abstract search-and-link concept into a specific technological solution:
- Claim 4 required the first application to be "active" and the second application to remain "non-active" throughout the process—creating a "constrained method where a user stays in one active application while the system surfaces only the corresponding results from a different application that remains non-active."
- Claim 5 further narrowed the method with an architectural constraint of a "unified Personal Information Manager on top of an enforced background operation."
- Claim 6 added security architecture, restricting the method to "perform cross-application linking inside a secure application ecosystem."
The court drew heavily on the Federal Circuit's decision, which held that the challenged claim improved a user interface.
Why This Matters
This decision is a pointed reminder that broad, functionally drafted software claims remain highly vulnerable to early dismissal. At the same time, the ruling shows that well-crafted dependent claims with concrete architectural constraints can save a case—and potentially a patent portfolio's value.
What You Should Do
- Audit your existing patents. If your software or technology patents rely on broad independent claims that describe results rather than specific methods or structures, evaluate whether your dependent claims provide enough specificity to withstand a Section 101 challenge.
- Draft with specificity from the start. When preparing new patent applications, build architectural constraints into your independent claims, not just dependent ones.
- Leverage dependent claims strategically in litigation. This case demonstrates that asserting dependent claims alongside (or instead of) broad independent claims can be the difference between surviving a motion to dismiss and losing your case at the outset.
- Reassess portfolio risk. Companies on either side of patent disputes should use this decision as a benchmark for evaluating the strength of software method claims, particularly those involving search, data linking, or cross-application functionality.
For more information on how this ruling may affect your patent strategy, please contact Chris Clayton or the Stinson LLP contact with whom you regularly work.
