Yieldmo v. Teads: Three Ad Format Patents Invalidated on § 101 in 178 Days
Yieldmo, Inc. filed suit in the Southern District of New York alleging that Teads’s inRead Video, Cinemagraph, Flow, and Scrolling 3D Cube ad formats infringed three US patents covering interactive digital advertising. Judge Paul A. Engelmayer granted Teads’s motion to dismiss in under six months, ruling all three patents drawn to patent-ineligible subject matter under 35 U.S.C. § 101.
Ad Format Patent Suit Ends at Pleading Stage on § 101 Grounds
On January 24, 2025, Yieldmo, Inc. filed an infringement action against Teads, Inc. in the U.S. District Court for the Southern District of New York (Case No. 1:25-cv-00737), asserting three patents — US10832729B2, US11604918B2, and US10832730B2 — that purportedly cover proprietary interactive and scrolling digital advertising format technologies. The accused products included Teads Cinemagraph, Teads Flow, Teads inRead Video, Teads Format Framework Technology, Teads Scrolling 3D Cube, and Teads iFrame.
The case closed on July 21, 2025, when Judge Paul A. Engelmayer granted Teads’s motion to dismiss for failure to state a claim. The Court held that all three patents-in-suit are directed to patent-ineligible subject matter under 35 U.S.C. § 101, the constitutional and statutory provision that excludes abstract ideas from patent protection. Dismissal at the pleading stage on § 101 grounds — before discovery or claim construction — represents a complete defendant win and extinguishes Yieldmo’s infringement claims without the need for trial.
Resolution in 178 days is notably fast for multi-patent ad tech litigation, suggesting the Court found the § 101 deficiency clear on the face of the pleadings. What drove the outcome likely includes the nature of the claimed inventions — digital advertising display concepts that courts frequently characterise as abstract ideas implemented on generic computing infrastructure. The public record does not disclose whether Yieldmo intends to appeal or whether a settlement was discussed prior to the ruling, leaving open questions about the long-term enforceability of Yieldmo’s broader patent portfolio.
Filing to Case Terminated in 178 days
178 days — resolved at pleading stage, well before trial or claim construction
§ 101 dismissal: what the ruling means for both parties
§ 101 dismissal at pleading stage — no discovery required
Under the Alice/Mayo framework, courts may invalidate patents directed to abstract ideas before any factual development. By granting a Rule 12(b)(6) motion to dismiss, Judge Engelmayer concluded that Yieldmo’s patents fail the two-step eligibility test on their face — the claims are directed to an abstract idea and add no inventive concept. This is a merits ruling, not a procedural one, and has immediate preclusive effect on these specific claims.
§ 101 / Alice–Mayo frameworkYieldmo’s three patents rendered unenforceable against Teads
The dismissal extinguishes Yieldmo’s infringement claims against Teads for all three asserted patents. Because the holding is one of patent-ineligibility — not mere non-infringement — the ruling casts doubt on Yieldmo’s ability to enforce these same patents against other defendants without confronting the same § 101 bar. Yieldmo retains the right to appeal to the Federal Circuit, but will face the same eligibility analysis unless it can distinguish the district court’s reasoning.
Patents held patent-ineligibleTeads avoids discovery and trial with early § 101 win
Teads secured a full dismissal in under six months without entering claim construction or fact discovery, dramatically limiting litigation cost and business disruption. The ruling insulates all six accused ad products — Cinemagraph, Flow, inRead Video, Format Framework Technology, Scrolling 3D Cube, and iFrame — from liability under these patents. Teads’s strategy of attacking eligibility at the pleading stage via Loeb & Loeb and Sterlington proved decisive.
Defendant wins on § 101 MTDRuling raises the bar for ad-format patent enforcement across the sector
A § 101 dismissal in SDNY on interactive ad format patents signals that similar claims across the digital advertising ecosystem face elevated invalidity risk. Companies holding patents on display, scrolling, or interactive ad mechanics should audit claim language against Alice step two before filing suit. For ad tech defendants, this outcome reinforces early § 101 motions as a cost-effective first line of defence — particularly in the Southern District of New York.
Heightened § 101 risk for ad-format IPFull party and counsel information
| Role | Name | Type | Detail |
|---|---|---|---|
| Plaintiff | Yieldmo, Inc. | Company | Interactive ad-format technology company — holder of US10832729B2, US11604918B2, and US10832730B2Search in Eureka ↗ |
| Defendant | Teads, Inc. | Company | Global advertising technology platform offering inRead Video and premium ad format productsSearch in Eureka ↗ |
| Plaintiff counsel | C. Graham Gerst | Attorney | Counsel for Yieldmo, Inc.Search in Eureka ↗ |
| Plaintiff counsel | Michael Healy | Attorney | Counsel for Yieldmo, Inc.Search in Eureka ↗ |
| Plaintiff law firm | Global IP Law Group LLC | Law Firm | Representing Yieldmo, Inc.Search in Eureka ↗ |
| Defendant counsel | Brenton R. Babcock | Attorney | Counsel for Teads, Inc.Search in Eureka ↗ |
| Defendant counsel | Dan Liu | Attorney | Counsel for Teads, Inc.Search in Eureka ↗ |
| Defendant counsel | Ryan Neil Hagglund | Attorney | Counsel for Teads, Inc.Search in Eureka ↗ |
| Defendant law firm | Loeb & Loeb LLP | Law Firm | Representing Teads, Inc.Search in Eureka ↗ |
| Defendant law firm | Sterlington, PLLC | Law Firm | Representing Teads, Inc.Search in Eureka ↗ |
| Presiding judge | Judge Paul A. Engelmayer | Judge | New York Southern District CourtSearch in Eureka ↗ |
Official order — verbatim text
The Court’s order is unambiguous in scope: all three patents-in-suit were held patent-ineligible under § 101, and Teads’s motion to dismiss for failure to state a claim was granted in full. The phrase ‘for the foregoing reasons’ indicates the ruling is grounded in a detailed written analysis applying the Alice/Mayo two-step framework — meaning the § 101 deficiency was found at the claim level, not on procedural grounds. For Yieldmo, the ruling is a substantive loss with potential estoppel implications in any future enforcement action involving the same patents. For Teads, all accused products are cleared of liability under these three patents.
US10832729B2, US11604918B2 & US10832730B2 — Interactive Digital Ad Format Technologies
The three patents asserted by Yieldmo — US10832729B2, US11604918B2, and US10832730B2 — relate to interactive digital advertising formats, covering methods and systems for presenting, animating, and engaging users with ad content in web and app environments. The application dates span from the mid-2010s through the early 2020s, reflecting Yieldmo’s iterative development of proprietary ad delivery mechanics during a period of rapid growth in programmatic and mobile advertising. The technical domain sits at the intersection of display advertising, user interface interaction, and web-based media rendering.
These patents were commercially significant because they purported to cover format-level innovations — scrolling mechanics, in-stream video placement, and animated ad experiences — that are widely deployed across the digital advertising ecosystem. The accused Teads products, including inRead Video and the Scrolling 3D Cube format, are mainstream ad delivery vehicles used by major publishers globally. A successful infringement finding could have created licensing pressure across the programmatic advertising supply chain. The § 101 ruling, however, suggests the claims lacked the specificity needed to survive eligibility scrutiny, which is a common vulnerability in software and display-layer advertising patents.
Should you run an FTO against US10832729B2, US11604918B2, and US10832730B2?
Ad tech companies building or licensing interactive, scrolling, in-stream video, or animated advertising formats should be aware that while these three Yieldmo patents were invalidated in this action, the § 101 ruling is case-specific and not universally binding on other courts. If your product roadmap includes mechanics similar to inRead video, cinemagraph-style animations, or scrolling 3D ad units, a formal FTO analysis remains prudent — particularly if you operate in jurisdictions where Yieldmo or related entities hold corresponding foreign patents or continuation applications.
PatSnap Eureka’s FTO Search Agent can map the full Yieldmo patent family, identify active continuations or related applications, flag claim language that survived this litigation, and benchmark your ad format product against the asserted claims. Eureka also monitors the Federal Circuit docket for any appeal of this ruling, alerting you if the § 101 finding is revisited. For in-house IP teams at publishers, DSPs, and ad format vendors, this is a high-priority portfolio to track.
Run a freedom-to-operate analysis on US10832729B2 to assess your product’s exposure
Run FTO in Eureka →Similar § 101 Patent Dismissals in Digital Advertising Technology
Cases involving § 101 patent-ineligibility challenges to interactive ad format and programmatic advertising patents in U.S. district courts, including SDNY.
What this case signals for the ad technology IP landscape
The SDNY § 101 dismissal in Yieldmo v. Teads has direct implications for patent strategy across the digital advertising sector.
Ad format patents face acute § 101 risk at the pleading stage
Judge Engelmayer’s ruling confirms that interactive advertising format claims — scrolling, video, and animated display mechanics — are vulnerable to Alice-based dismissal before discovery. Patent holders in this space should stress-test eligibility before filing suit; defendants should consider § 101 as a first-priority defence.
Early MTD strategy delivered full resolution in under six months
Teads’s decision to move to dismiss on § 101 rather than invest in claim construction avoided months of discovery and substantial litigation cost. This case reinforces that a well-argued Rule 12(b)(6) motion on patent eligibility can resolve multi-patent ad tech disputes with surgical efficiency in SDNY.
Yieldmo v Teads — key questions answered
Yieldmo asserted US10832729B2, US11604918B2, and US10832730B2 — all covering interactive digital ad format technologies. Judge Engelmayer held all three patent-ineligible under 35 U.S.C. § 101, applying the Alice/Mayo framework and finding the claims directed to abstract ideas without a sufficient inventive concept.
A Rule 12(b)(6) dismissal on § 101 grounds is a merits ruling on patent eligibility. While not technically a judgment of invalidity binding on every future defendant, it creates significant persuasive authority in any future action on these patents. Other defendants facing the same patents can cite this ruling in their own § 101 challenges.
The case closed in 178 days from filing — under six months. Multi-patent district court cases typically run two to four years through trial. Resolution at the pleading stage via a § 101 motion to dismiss is substantially faster than the norm, and reflects the strength of Teads’s eligibility arguments on the face of the complaint.
The accused products were Teads Cinemagraph, Teads Flow, Teads Format Framework Technology, Teads Scrolling 3D Cube, Teads iFrame, and Teads inRead Video — all ad delivery and display format products used across Teads’s publisher and advertiser network.
Yes. A final judgment of dismissal from the Southern District of New York is appealable to the United States Court of Appeals for the Federal Circuit, which has exclusive jurisdiction over patent appeals. Yieldmo would need to argue that the district court misapplied the Alice/Mayo framework. As of the available public record, no appeal has been confirmed.
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