Recentive Analytics v. Fox Corp. — Supreme Court Petition Denied in 48 Days
Recentive Analytics petitioned the U.S. Supreme Court to review its infringement claims against Fox Corp. covering four machine-learning patents for automated network mapping and event scheduling. The Court denied the petition in just 48 days, closing the door on further federal review and leaving the lower court outcome undisturbed.
Supreme Court shuts down Recentive’s ML patent campaign against Fox
Recentive Analytics filed a petition for certiorari before the U.S. Supreme Court on 21 October 2025, seeking review of lower-court findings adverse to its four patents — US11386367B1, US11537960B2, US10958957B1, and US10911811B1 — which collectively cover systems and methods for AI-driven network map generation and automated event schedule determination. The respondent, Fox Corp., opposed the petition through counsel at Pillsbury Winthrop Shaw Pittman LLP.
The Supreme Court denied the petition on 8 December 2025, terminating the case after only 48 days. A denial of certiorari carries no precedential weight on the merits — it signals only that fewer than four Justices voted to grant review — but it is nonetheless final: Recentive has exhausted its federal appellate remedies for this set of patents against this defendant. The lower court’s disposition of the infringement claims accordingly stands.
The 48-day window from filing to denial is consistent with a summary denial without full briefing or oral argument, suggesting the Court saw no certworthy question — no circuit split, no issue of exceptional importance, or no vehicle problem sufficiently compelling. The public record does not disclose the precise grounds on which the lower court ruled, nor whether eligibility under 35 U.S.C. § 101 or another doctrine drove the adverse outcome Recentive sought to reverse.
Filing to Petition Dismissed in 48 days
48 days — exceptionally brief for a Supreme Court petition cycle
Supreme Court denies certiorari: what the ruling means for both parties
Cert denied: no merits ruling, but the case is closed
A denial of certiorari by the U.S. Supreme Court is not a ruling on the merits. The Court simply declined to exercise discretionary review. However, it is procedurally final: no higher federal tribunal exists. The lower court’s judgment — adverse to Recentive — remains in full force, and no further appeal is available within the federal system on these patents against Fox Corp.
Certiorari denied — no merits adjudicationRecentive’s patent campaign against Fox ends without vindication
For Recentive Analytics, the denial forecloses any prospect of reversing the lower court’s adverse disposition of its four ML patents in this action. The patents themselves are not formally invalidated by the denial, but their enforceability against Fox Corp. is settled. Recentive may still assert these patents in separate proceedings against other defendants, though the lower court ruling may carry persuasive weight.
Federal remedies exhausted vs. Fox Corp.Fox Corp. secures finality on all four asserted patents
Fox Corp. emerges with a final, unappealable outcome in its favour. The denial means no remand, no further proceedings, and no residual liability exposure on these four patents from this plaintiff in this action. The result also consolidates Fox’s legal position should Recentive — or an assignee — attempt to assert these patents against other Fox entities or products.
Full finality secured for Fox Corp.ML-based scheduling patents face a chilling headwind post-denial
The Supreme Court’s refusal to intervene suggests the lower court’s reasoning on ML-applied patent eligibility or infringement has survived the highest level of scrutiny available. Competitors developing AI-generated network mapping or automated event-scheduling systems should treat the lower court ruling as a live precedent when assessing their own patent strategies or FTO positions in this technology category.
Heightened risk for AI scheduling patent holdersFull party and counsel information
| Role | Name | Type | Detail |
|---|---|---|---|
| Plaintiff | Recentive Analytics | Individual | AI-driven media scheduling analytics company — holder of US11386367B1 and three related ML patentsSearch in Eureka ↗ |
| Defendant | Fox, Corp. | Company | Fox Corp. — major U.S. media and broadcasting conglomerate, represented by Pillsbury Winthrop Shaw Pittman LLPSearch in Eureka ↗ |
| Plaintiff counsel | Lauren Jarvis Dreyer | Attorney | Counsel for Recentive AnalyticsSearch in Eureka ↗ |
| Plaintiff law firm | Baker Botts LLP | Law Firm | Representing Recentive AnalyticsSearch in Eureka ↗ |
| Defendant counsel | Evan Finkel | Attorney | Counsel for Fox, Corp.Search in Eureka ↗ |
| Defendant law firm | Pillsbury Winthrop Shaw Pittman LLP | Law Firm | Representing Fox, Corp.Search in Eureka ↗ |
| Presiding judge | Judge N/A | Judge | U.S. Supreme CourtSearch in Eureka ↗ |
Official order — verbatim text
The Supreme Court’s entry ‘Petition DENIED’ carries no opinion and no statement of reasons, as is standard practice for cert denials. It does not affirm the correctness of the lower court and creates no binding precedent. Nonetheless, the denial is the operative endpoint: the lower court’s ruling on Recentive’s four machine-learning patents — covering automated network mapping and event scheduling — now stands as the final word in this dispute. For practitioners, the significance lies not in the cert denial itself but in the lower-court reasoning that survived it.
US11386367B1 — AI-Driven Network Map and Event Schedule Generation
The four patents at issue — US11386367B1, US11537960B2, US10958957B1, and US10911811B1 — cover systems and methods applying machine-learning techniques to automate the generation of broadcast network maps and the determination of event schedules. The application numbers (filed under US17/332144, US17/857597, US17/112110, and US16/598480) indicate a family of related inventions prosecuted across 2020–2022, a period of heightened regulatory and commercial interest in AI-assisted media scheduling.
For the media and broadcasting sector, patents in this cluster sit at the intersection of two high-value IP battlegrounds: AI/ML patent eligibility under § 101 and the commercial value of algorithmic scheduling in live television and streaming. Fox Corp.’s successful defence signals that these claims — as drafted — may not have sufficiently distinguished ML-applied scheduling from abstract-idea doctrine. Competitors with similar IP portfolios should audit claim language for concrete technical improvements beyond applying AI to conventional scheduling workflows.
Should you run an FTO analysis against these four Recentive ML patents?
Any company building AI-powered broadcast scheduling, automated network map generation, or ML-driven event programming systems should assess its exposure to this patent family. Although Fox Corp. successfully defeated these claims, the patents remain in force and could be asserted against entities that lack Fox’s litigation resources or whose products differ materially from Fox’s. R&D teams developing similar systems should confirm whether their architectures fall within the asserted claim scope.
PatSnap Eureka’s FTO Search Agent can map your product’s technical features against the claim language of US11386367B1 and the related family members, identify prior art that informed the lower court’s findings, and flag any continuation applications that may pose residual risk. Upload your product specification or patent application to generate a structured FTO report across this patent family in minutes.
Run a freedom-to-operate analysis on US11386367B1 to assess your product’s exposure
Run FTO in Eureka →Similar Supreme Court certiorari denials in AI and machine-learning patent disputes
Browse related cases where ML and AI-based media or scheduling patents were challenged through federal courts and the U.S. Supreme Court declined review.
What this case signals for the AI-driven media technology IP landscape
The swift cert denial caps a patent enforcement effort centred on machine-learning media scheduling — with lasting implications for how such patents are valued and asserted.
Cert denials do not invalidate patents — but they do signal litigation risk
Recentive’s four ML patents remain technically in force. However, any future licensee or acquirer must price in that these patents failed at every federal level against a well-resourced defendant. For portfolio valuation purposes, the lower court’s adverse ruling — now unreviewed — is the operative legal benchmark.
AI-generated scheduling claims face § 101 scrutiny — build prosecution records accordingly
Cases in this technology cluster consistently attract patent-eligibility challenges. Companies with pending applications covering machine-learning event scheduling or network optimisation should ensure their prosecution records emphasise concrete technical improvements, not merely applying ML to known problems — a distinction courts in this area treat as dispositive.
Analytics v Fox — key questions answered
The denial means the Supreme Court declined to review the lower court’s ruling. It is not a merits decision and sets no precedent, but it is procedurally final. Recentive has exhausted its federal appellate options for these four patents against Fox Corp., and the lower court’s adverse disposition stands.
Recentive asserted four patents: US11386367B1, US11537960B2, US10958957B1, and US10911811B1. All cover systems and methods using machine learning to automatically generate broadcast network maps and determine event schedules. The applications were filed between 2019 and 2022.
No. A certiorari denial does not invalidate patents. The four patents remain in force. However, the lower court’s adverse ruling — left undisturbed by the Supreme Court — may carry persuasive weight in any future enforcement action against other defendants or in any IPR proceedings.
The case was filed on 21 October 2025 and closed on 8 December 2025 — a span of just 48 days. This timeline is consistent with a summary cert denial issued without full merits briefing or oral argument, suggesting no Justice found the petition to present a certworthy question.
Companies in AI-driven media scheduling should treat the lower court ruling as a live data point on patent eligibility risk for ML-applied claims in this space. Pending applications should emphasise concrete technical improvements. FTO analyses against the Recentive patent family remain advisable for any product operating in automated network map generation or event scheduling.
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